القانون الواجب التطبيق على أهلية الملتزم بالورقة التجارية : دراسة مقارنة

الملخص EN

Due to the increase in the use of commercial paper in the scope of international private relations as it is linked to the increase in the movement of international trade and growth، which requires consideration of the provisions relating to the competence of the obligor in the paper, especially since the international conventions in this regard did not eliminate the cases of conflict altogether، which led to the survival of cases of conflict of laws On the competence of the obligor or those who are bound by the commercial paper in particular، and that the rules of attribution contained in the Civil Code are incapable of providing solutions Noting that the national law may be limited to providing adequate protection to those dealing with commercial papers، which necessitates the search for a base of other voluntary assignations، taking into account the gradation from rule to exception and rule Such attribution is the place of moral obligation in the event of the failure of personal law.