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    STUDIA IURISPRUDENTIA - Issue no. 3 / 2009  
         
  Article:   MATRIMONIAL CONVENTIONS AND SAME-SEX MARRIAGES. COMPARING THE NETHERLANDS, ENGLAND AND USA LAW.

Authors:  OVIDIU-IOAN PETRENCIU. 		 
       
         
  Abstract:  The present research focuses on two of the most controversial topics of law of matrimonial relations nowadays: the matrimonial conventions and same-sex marriages. Both of these law institutions and the values that justify them are in progressive changing all over the world and especially in Europe. However the Romanian law system, at the moment of writing, does not recognise these institutions and a comparative research can provide us better perspectives. I will try to cover the law figures from above by comparing the law from two states of Europe, Netherlands and England, and the law of USA. For the understanding of the marriage agreements and the same-sex marriage it is crucial to analyse the basic principles of the matrimonial imperative regimes in each of the compared system. The main question of the research is: Which of the compared systems of law provides the highest liberty for entering into marriage agreements or same-sex marriages?

Keywords: family, marriage, matrimonial conventions, comparative law
  
         
     
         
         
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