Multi-rule state

A Multi-unit State is a State in which different for different sub-areas or groups of people right applies. The term is mostly related to private law .

Multi- law states with territorial divisions are often federal states . Typical multi-law states with territorially divided private law are, for example, in the Anglo-American area the United Kingdom , the USA , Canada and Australia ; in the continental European legal circle the Kingdom of the Netherlands , Spain ( formal rights ) and Mexico (based on the US model); also Ethiopia ; from the former socialist legal system the Soviet Union and Yugoslavia . The interlocal private law determines which territorial partial legal order applies in a specific case . With regard to administrative law , Germany is also largely a multi-law state with a division of territorial law.

The legal division of the law is often religious, sometimes also ethnic (e.g. Adatrecht in Indonesia). In private law, family and inheritance law are particularly affected. Many Islamic states are multi -law states with a personal division of law, whereby different schools of law have to be distinguished. Typical examples are Egypt , India or Israel ; This does not include the successor states of the Soviet Union or Tunisia (since 1957). Interpersonal (interreligious) private law determines which partial legal system is to be applied in a specific case .

If the German IPR refers to a multi-law state without specifying the relevant partial legal system, a sub- connection is required . If there is a lack of interlocal / interpersonal conflict of laws in foreign law, "the partial legal system with which the matter is most closely connected is to be applied" ( Art. 4 Para. 3 Sentence 2 EGBGB ; corresponding to Austrian IPRG § 5 Para. 3 Sentence 2 ) .

For the legal sociological phenomenon, see legal pluralism .