عنوان مقاله [English]
نویسندگان [English]چکیده [English]
Determining the governing law on obligations of the commercial instruments ,and what criteria existsfor determining the governingin law inthe case of their mutual agreement or silence , is one of the most significant problems with which the investigator faces. In this article, it was attempted to examine the theories used for Determining the qualified law of obligations of the commercial instruments so as to remove the defect of the rules of Irans conflict resolution in terms of governing law over such documents , and it was proved that to resolve the conflicts related to the governing law occurring at International level , instead of exerting one law on all obligations in one document, it is possible to use various laws in a bid to create a single rule for removing the conflict. Also, in exerting the principle of governing will determination in determining the governing law it has been proposed that article 968 of the civil code be recognized as optional or be amended and the disturbing and disorganizing expression ((foreign nationals)) be omitted from the above mentioned article.