المسئولية التقصيرية الناشئة عن ازدراء الدين الإسلامي : دراسة مقارنة.

الملخص EN

Arab lawmakers have deliberately confronted the crime of contempt religions especially the Islamic religion - by codifying explicit criminal texts, Through it, they identified forms of the material element that represent an attack on religions, and the penalties that would be inflicted on the perpetrator, Consistent with the principle imposed by criminal responsibility, Which states that: »Nullum crimen, nulla poena sine lege«, Which contradicts with the nature of civil responsibility, which establishes a principle that: »Each fault that has caused damage to others shall be indemnified by the perpetrator thereof« Without Legislative inventory to the forms of that fault or this damage, This research has try to accentuate the elements of Tort Liability arising from contempt of the Islamic religion, from fault, damage, and causal relationship, through the method of comparison between Egyptian, Algerian and French law.