Some recent developments in family law in several countries : from a perspective of private international law

点击翻译按钮获取中文摘要

The legal recognition of same-sex marriage or surrogacy has gradually emerged in the law of several European countries and the United States of America. The purpose of this research is to examine how these new institutions for legally recognizing same-sex marriage including registered partnership and surrogacy should be considered under Japanese Private International Law. Some recent development of these new institutions transformed the traditional method of Private International Law. The method of bilateralism or recognition of foreign judgment does not make available these new institutions. Through the influence of recent European discussion on the mutual recognition principle, it may be said that an exceptional method such as the mutual recognition principle is preferable to these new institutions.