تعارض چند قانون ملي در مورد ازدواج و طلاق

Conflict of Several National Laws in the Field of Marriage and Divorce

In private international law there are two different solutions relating to persqnal status of individuals. In some countries, the accepted rule is that personal status of individuals are basically governed by their national law, While in others, the applicable law is the law of their domicile. Conflict of several national laws occurs in the courts of countries where the applicable law in matters of personal status is the national law of the individuals, just as conflict of nationalities, whose resolution is prior to the conflict of laws occurs in the same courts. The effect of nationality on marriage and vice versa also arises in countries where the personal status of individnals are governed by their national law. In this paper the causes and grounds of conflict among several national laws are examined and the solution for resolving the conflict is also proposed.