Chapter 7: France
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This Chapter deals with the legal notion of international public policy taken from the French perspective. Distinguished from other close mechanisms, the notion is defined, answering in French to a dual meaning. It refers either to the conflict of laws exception tool itself (l'exception d'ordre public), or to the content of the French values at a given time (the standards), which are considered for a possible eviction of the foreign law. The increasing use of the concept of local public policy (ordre public de proximité) in French case law is underlined as the intensity of reaction of international public policy now varies in France according to a proximity link depending on the strength of the link of a situation with the French system. Specific applications of French international public policy are then reviewed. The confrontation with laws of very different inspirations, especially reflected by the reception in France of Muslim law institutions, mainly by means of opposition to Moroccan and Algerian law which are most apparent in the field of family, is addressed. In conclusion, the French courts' review is assessed, between a lowering of the barriers of public policy on one hand and a systematic control that would impede cultural diversity and international harmony of private law relations, on the other hand.

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