Another attempt at a comprehensive codification of French private international law

Abstract

In France, the elaboration of a separate code of private international law started in 2018. Some elements of the rules of French law on private international law are currently contained in different pieces of legislation. However, the main part of French private international law has been developed by the French judicature. The sporadicity of private international law provisions and the key role of judicial practice make it a dangerous field for non-French lawyers, and it is therefore not surprising that French law is rarely designated as neutral, third-country law. As a result of the process started in 2018, the text of the draft law was finished for spring 2022, reflecting both foreign experience in codification of private international law and the Union's efforts to unify the law. The author describes the history of the draft, bearing in mind that there had been three attempts to codify private international law in France in recent decades, but all three had been unsuccessful. The author analyses the provisions of the General part of the draft Code, drawing parallels with Hungarian private international law.