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Law and morals in the application of the public policy exception under the twin regulations 1103 and 1104 of 2016

2021

This paper discusses the interactions between fundamental principles of domestic legal systems and non-legal standards in the application of the public policy Generalklausel within the context of the twin Regulations 1103 and 1104 of 2016. In particular, this paper argues that public policy is composed of legal principles only and that there is no space for extra legal standards when the circulation of foreign deeds, decisions and laws is in discussion. This consideration has two consequences. Firstly, the role of good morals within contemporary private international law is extremely reduc

:CIENCIAS JURÍDICAS [UNESCO]Soft Law. 324 349Soft Law.Derechodecisions and laws is in discussion. This consideration has two consequences. FirstlyAnulación de las reglas obligatoriasBuena fePublic PolicyGood MoralsGeneralklauselnMoralGiovanni This paper discusses the interactions between fundamental principles of domestic legal systems and non-legal standards in the application of the public policy Generalklausel within the context of the twin Regulations 1103 and 1104 of 2016. In particular2386-4567 22661 Actualidad jurídica iberoamericana 587897 2021 15 8113565 Law and morals in the application of the public policy exception under the twin regulations 1103 and 1104 of 2016 ZarraOverriding Mandatory RulesOrden públicoUNESCO::CIENCIAS JURÍDICASthis paper argues that public policy is composed of legal principles only and that there is no space for extra legal standards when the circulation of foreign deedsthe role of good morals within contemporary private international law is extremely reduc Morals
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