Application of private international law is impossible without deciphering the meaning of the legal rules specific to this branch or without classifying the test cases on categories. This dual mental operation that the judge has to do is called qualification. The notion of qualification is...

The effects of marriage are brought under regulation in the Civil Code in Title II entitled “Marriage” Chapter V is dedicated to personal rights and duties of spouses (art.307-311) and Chapter VI is dedicated to property rights and obligations of spouses (art.312-372). Also, the Civil Code...

The provisions of art. 312 of the Civil Code establish: a legal system, that is the community property regime and two types of conventional regimes: the regime of separation of goods and the regime of conventional community (the latter includes conventional derogation from community property...