موقف الفقه الأمريكي و الأوروبي من أزمة منهج التنازع

الملخص EN

Excessive reliance on the rules of conflict in resolving international private relations disputes showed the failure of this approach to comprehend the requirements of international dealings, Which led to placing this approach in a difficult position and revealed the mask of the serious flaws that characterize its rules, Some likened it to a coup in the science of private international law, This prompted legal jurisprudence in America and Europe to direct arrows of criticism for this approach, Proposing some alternatives that they thought were capable of overcoming the deficiencies that were recorded on the traditional conflict approach.