القانون الواجب التطبيق على انحلال الزواج المختلط: دراسة مقارنة بين التشريع الجزائري والمقارن

Abstract EN

The dissolution of mixed marriages is one of the most important issues of personal satus and is an area of conflict of laws, given the social, it religious and moral considerations underlying marriage, and because of the difference in society's perception of it.

The difference of countries in their view of the dissolution of the marital union led to the difference in the laws in determining the rules of attribution that governs, somes countries assigned the dissolution the rules of marriage to the law of the nationality of the husbandat the time of the lawsuit, while the other Arab legislation separated divorce by the individual will of the husband at the time of filing the suit.

In the case of a difference of nationality, the common home lawshallapply, otherwise the law of the judge.