Conflicts of procedures and decisions in private international law.

Summary As the law stands, the conflict of laws model dominates the settlement of conflicts of procedure and decision. The principled solution to these conflicts is the application of the prior tempore, potior jure rule. While this analysis is perfectly well founded with regard to conflicts of procedure and decision that develop in a state or inter-state judicial area, the situation is different with regard to those that occur in the international area. In this second hypothesis, these conflicts belong to the category of conflicts between legal orders whose resolution depends on international judicial competence. The solution implemented in this case lies in determining the most competent forum. The chronological criterion is therefore only of a subsidiary nature.