Conflict of Laws in Surrogacy Cases: A Comparative Study Between French Private International Law and Arab Legal Systems
Bibliographic record
Abstract
Surrogacy is one of the most prominent issues in reproductive rights, at its core it interferes with fundamental rights and the integrity of the most intimate human choice, the procreation of the human species. Surrogacy or “reproductive tourism” is said to be an artificial conception made possible through scientific techniques employed through the direct or indirect involvement of a surrogate mother. Surrogacy is permitted in some countries such as Canada, Georgia, India, Mexico, the Netherlands and the United States, while it is barred by law in others such as Norway, Italy, Sweden, Germany and France. The legal rivalry towards surrogacy raises an essential issue: what is the legal effect when a child enters a country that prohibits such an agreement? This question becomes even more difficult when confronted with the multiplication of the states’ respective laws and their interstellar reach. The paper analyzes these questions through case studies found in both French and Arab legal systems. This interest in jurisdictions that historically approach the same coldness towards procreative contract is heightened by their recent growth in international commercial law. However, while there are common points in the analysis of the outcomes, the rigidity of the French State is contrasted with the enduring flexibility in Arab states. The final question this paper endeavors to answer is whether such flexibility is ideal. What does the future hold in a world befuddled by state confrontations and travel bans
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.008 | 0.020 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.007 | 0.008 |
| Science and technology studies | 0.007 | 0.008 |
| Scholarly communication | 0.009 | 0.003 |
| Open science | 0.001 | 0.003 |
| Research integrity | 0.003 | 0.001 |
| Insufficient payload (model declined to judge) | 0.007 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".