نوع مقاله : مقاله پژوهشی
عنوان مقاله English
نویسنده English
In contrast to national law with the multiplicity of bilateral systems in which they seek to solve the problems of the scope of the law in which the relation is due to its nature. as well as variety of conflict resolution methods,grounds for the emergence and occurrence of renvoi of place of dialogue.With multiple systems. Justification for first-degree renvoi and the principle of accepting second-degree renvoi and with variety of systems its existential principle is problematic.solution can be provided to solve problems by descriptive-analytical method and by using the data of comparative law:In contrast to bilateral systems, one should not insist on one of two criteria"coordination of solutions" and"rule of dispute resolution of the seat of court".What is criterion of being the first to reduce the number of renvoi acceptances much, and thereupon, is reduce in speed and accuracy and obstacle to identification of Votes and the compass point of the second case brings with it the inconsistency of the solutions.In contrast to variety of methods, must be approved unilateral rule,without reference to foreign law, specifies the scope of country's law in place.So if the external rule is unilateral, renvoi and if the Iranian rule is unilateral, if Iranian rule is unilateral,comission and thereupon no renvoi. In the method of purposeful rules and Selection of the Appropriate Law wanted to establish the rule is competent substantive law. In these circumstances, occurrence or continuation of renvoi, depending on the benefit of court headquarters system or cause of such methods, isn’t appropriate.
کلیدواژهها English
