وضعية مدونة الأسرة المغربية في الأنظمة القضائية الأوربية

الملخص EN

One of the recognized principles in private international law is that the judge before whom the dispute is brought resolves the conflict of laws according to the rules of attribution contained in the law of the country in whose name he rules ; this means that the foreign judge does not apply moroccan family law voluntarily, but rather does so in compliance with the order of his national legislator under the rules of attribution contained in his internal law.

these rules of attribution are either national, and the national legislator is unique in defining them according to his orientations and perceptions in dealing with the phenomenon of migration; either it is the subject of an agreement between two or more countries within the framework of an agreement that brings them together.