A comparative analysis of conflict-of-laws rules governing personal status in the legal systems of Iran and Afghanistan

Development summary

This Zenodo article offers a comparative analysis of the conflict-of-laws rules governing personal status in the legal systems of Iran and Afghanistan. It examines the connecting factors used to determine the applicable law for marriage, divorce, parent–child relations, guardianship, tutorship and legal capacity, with particular attention to nationality as the main connecting factor in both jurisdictions and to issues of public policy, multiple nationality, statelessness and cross-border family relations. The authors report that both systems remain largely nationality-based, while also noting differences in scope, judicial interpretation and the handling of contemporary transnational disputes.