سلطة القاضي الناظر بالنزاع في تجريد اختصاص القضاء الوطني: دراسة مقارنة

الملخص EN

The authority of the judge embodied in strip the competent national court of its international judicial jurisdiction in favor of another foreign court, and to a different extent, either the judge refers the case after individuals adhere to the referral for the same case before the foreign court, or they adhere to the negative agreement of jurisdiction, or his authority may be limited to the extent of accepting the implementation of the foreign judgment or rejecting it after stripping the jurisdiction of voluntary submission, while limiting it to defining the role of the national judge in facing the negative will of jurisdiction.

the study reached a set of results and proposals that were mentioned in the conclusion of the research.