PUBLIC POLICY CLAUSE IN PRIVATE INTERNATIONAL LAW
Journal Title: Вісник Одеського національного університету. Правознавство - Year 2014, Vol 19, Issue 4
Abstract
The article gives an overview of one of the mechanisms for the protection of ordre public which to prevent the devastating effects of foreign law on national public policy — a public policy clause. The analysis of nature and character of the wording of national norms of different countries shows that provisions aimed at protecting national public policy may be constructed differently. The world practice knows two concepts of clause of ordre public: positive and negative, and the negative concept of public policy clause is dominant in contemporary private international law.
Authors and Affiliations
O. N. Nagush
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