مشكلات تحديد القانون الواجب التطبيق على المسؤولية المترتبة عن الفعل الضار : دراسة مقارنة

الملخص EN

Law arrange harmful acts Civic responsibility to give the airgrieved the Asking of right to Compensation and that's Where the Source of Such Commitments is the law not the will of the people So that the Contract Which We tallcing about Come out the optional lous and within the Scope of man datory laws And Can fined to Confilcts between the place of Commission of tort law and the law of the Court raised the dispute before them have faced determine provincial process in Which the Tort occurred difficulties for Aashi avoided Will highligh them.

We will confirm very harmful acts or Tort as one of the most important of these Commitments in practice base is Contested in this regard , there have been significant developments despite the fact that Some of the Laws , especially Araly ones still Sticking to traditional rules is insensitive to What the face of their Criticism.

After a Competent law reached to resolve the dispute in the illicit business , this law is also decide the concern terms of responsibility as the existence of error or not and Check the existence of the damage and the amout and quality as if the material or moral and After that Causal relationship between them.