الدفع بالنظام العام في منازعات الميراث و الوصية ذات البعد الدولي

Abstract EN

If the Algerian legislator and Comparative Arab legislations has licensed the national judge to apply foreign law on foreign to disputes that include a foreign element whenever indicated by the rules of ratachment in the law.

However, it prevents him from applying this law, if he determines that its content is contrary to public order in his country.

The inheritance and wills in Algeria system and most of the Arab countries is derived from the provisions of the Sharia, and it will result in the application of national law and the exclusion of the competent foreign law, whenever the latter contained provisions inconsistent with the provisions of the Sharia.