PRAWO WŁAŚCIWE DLA OCHRONY DOBREGO IMIENIA I DÓBR OSOBISTYCH OSÓB FIZYCZNYCH W POLSKIM I AMERYKAŃSKIM PRAWIE KOLIZYJNYM
THE GOVERNING LAW FOR THE PROTECTION OF THE REPUTATION AND PERSONAL RIGHTS OF INDIVIDUALS IN POLISH AND AMERICAN CONFLICT LAW

Summary/Abstract: The issue of the law applicable to the protection of reputation and personal rights is a topical issue in both Polish and American conflict of laws. For each of these laws for common, universal reasons as well as individual ones resulting from the historical context. Thus, starting from a delineation of the main theses by defining concepts, attention was paid to the main concepts and theories in both systems based on the current views of doctrine and jurisprudence taking into account the tendency to harmonise international and substantive law. A problem analysis of the Polish conflict of laws regulation is presented, pointing out its significant shortcomings which, in certain situations concerning personal statutes, may determine the applicable law. The solutions were juxtaposed with the non-uniform American conflict-of-law system in order to answer the question of predictability of this law and to indicate the problem of applicable law. In conclusion, some concluding remarks of the study and the views of the doctrine are put forward.

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