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Academic literature on the topic 'Droit comparé français-québécois'
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Journal articles on the topic "Droit comparé français-québécois"
Jobin, Pierre-Gabriel. "Le droit comparé dans la réforme du Code civil du Québec et sa première interprétation." Les Cahiers de droit 38, no. 3 (April 12, 2005): 477–501. http://dx.doi.org/10.7202/043453ar.
Full textFokou, Éric. "La notion d’économie du contrat en droit français et québécois." Revue générale de droit 46, no. 2 (January 11, 2017): 343–77. http://dx.doi.org/10.7202/1038621ar.
Full textVergès, Etienne, and Lara Khoury. "Le traitement judiciaire de la preuve scientifique : une modélisation des attitudes du juge face à la connaissance scientifique en droit de la responsabilité civile." Les Cahiers de droit 58, no. 3 (September 12, 2017): 517–48. http://dx.doi.org/10.7202/1041010ar.
Full textPourbaix, Marie-Noëlle. "L’abandon d’enfants : du Québec à la France en passant par l’Ontario." Revue générale de droit 29, no. 2 (March 18, 2016): 133–207. http://dx.doi.org/10.7202/1035675ar.
Full textOuedraogo, Richard. "La prohibition en droit français des conventions de procréation et de gestation pour le compte d’autrui : analyse critique à partir de quelques observations du droit québécois." Revue générale de droit 45, no. 1 (July 8, 2015): 269–320. http://dx.doi.org/10.7202/1032040ar.
Full textDissertations / Theses on the topic "Droit comparé français-québécois"
Vezina, Nathalie. "L'obligation de sécurité : Etude de droit comparé (droits français et québécois)." Paris 2, 2006. http://www.theses.fr/2006PA020022.
Full textLandheer-Cieslak, Christelle. "La religion devant les juges français et québécois de droit civil." Paris 1, 2005. http://www.theses.fr/2005PA010285.
Full textMaameri, Amira. "La participation du mineur à sa propre protection : droit comparé français-québécois." Electronic Thesis or Diss., Bordeaux, 2024. http://www.theses.fr/2024BORD0189.
Full textAs regards child protection, speech of participation of the minor in his own protection is to consider this one like a subject of active right and not only like one object of protection. In this direction, the International Convention of the Children's rights affirmed the capacity of the child to be taken part in his own protection, guaranteed by its right to the expression. Consequently, the child to be protected is not simply any more perceived like a vulnerable human being requiring a State aid (passive subject of right), before the placement, during and after this one. The minor is recognized as a citizen in becoming ( active subject of right) to which a series of rights are conferred such as the right to take part in the decisions which relate to it according to its age and its degree of understanding, the right to freedom to think, of conscience and religion or the right to reach information diversified and aiming at promoting its wellness physics, mental and social. Accordingly, it is by the means of the exercise of its rights that the protected child can become the actor of his own protection
Brochu, François. "La publicité foncière et la prescription acquisitive en droit civil québécois à la lumière du droit français, suisse, allemand et australien." Aix-Marseille 3, 1997. http://www.theses.fr/1997AIX32007.
Full textThe new civil code of quebec, which came into effect on january ist 1994, has considerably limited the function of acquisitive prescription by giving new powers to publicity of rights. Indeed, although quebec's law has kept the conventional transfer of real estate element, the registration of rights in the land register will create an irrefutable presumption of their existence after ten years, when the setting up of the new system of publication by registration in the land register will be done. Also, those carrying out transactions for an immovable will be able-if they are in good faith - to rely on the entries in the land register. Inspired by swiss law, australian law and alsatian law, quebec's reform of its law on publication by registration in the land register has kept the acquisitive prescription as well as each of these countries. Even if the resort to prescription will in fact not be as popular as in french law or as under the civil code of lower canada's system, it will be possible, with the prescription, to avoid for the inscription of rights in the land register to lead to deadlock if, for instance, the registered holder of a right is absent or dead. The quebec's publication by registration in the land register was powerless without the complementarity of the prescription but it could become pressing without acquistive prescription. Maybe quebec's reform will be an example to the french legislator
Gervais, Stéphanie. "Les mauvais traitements à enfants en droit comparé : français, anglais et québécois : de la difficulté à les déterminer et à les dévoiler." Poitiers, 1998. http://www.theses.fr/1998POIT3005.
Full textKadima-Kabeya, Stanislas. "L'expertise médicale devant le tribunal, étude législative comparée du droit québécois et du droit français." Thesis, National Library of Canada = Bibliothèque nationale du Canada, 1997. http://www.collectionscanada.ca/obj/s4/f2/dsk2/ftp04/mq21772.pdf.
Full textPotvin, Louise 1951. "La personne et la protection de son image : etude comparée des droits québécois, français et de la common law canadienne." Thesis, McGill University, 1989. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=75976.
Full textThe first part of the thesis deals with the basis in law for the protection of the human likeness, while the second part attempts to determine how effectively individuals are protected from the publication of their likeness.
A comparison of the various solutions provided under the laws being examined has enabled us to determine whether one of them best safeguards the individual from the unauthorized publication of his or her likeness.
Ougier, Stéphanie. "L'alimentaire et l'indemnitaire dans les règlements pécuniaires entre époux consécutifs au divorce - étude comparée de droit français et de droit canadien." Thesis, Paris 2, 2015. http://www.theses.fr/2015PA020031/document.
Full textHistorically post-divorce laws between spouses was based in France, Canada and Quebec on penalizing the responsible party of the separation. Although from different law traditions, Canadian and French law recognized an important place to the fault in their divorce laws. However, the tendency of the French and Canadian societies to be more individual and to pacify conflicts, divorce law had to change to become more objectivized. The movement of removing the fault in divorce permitted the creation of new institutions based on compensation, equity and solidarity which is symbolized by spousal support and alimony. The studied laws are characterized by diverse institutions, are founded on different grounds. These institutions inspired by different law traditions are thus very similar such as the Canadian on compensatory spousal support and the French compensatory obligation that we call "alimony compensatory obligation". This diversity impose us to think about the possibility of a renewal and rationalization of the existent institutions in order to be simplified and comprehensible for the future divorce spouses. A greater freedom of contract should also ensure the appropriation of the divorce's consequences by the divorced spouse with help of lawyers, mediators and judges. Once the divorce humanized, the question of the pacification of the dissolution/ ruptures of other types of union such as common law marriage or civil partnership. The increasing number of those new couples, it is becoming a necessity to take in consideration the consequences of their dissolution and draw a new common law for their dissolution
Nassarah, Eric Arnaud. "Le secret sacramentel à l'épreuve du durcissement de la répression de la pédophilie : proposition de réforme du droit québécois à la lumière du droit français." Thèse, 2017. http://hdl.handle.net/1866/19281.
Full textThe traditional relationship between criminal responsibility and sacramental secrecy has given way to a controversial new report. Modernization, the secularization of societies, the need to adapt justice to the growing need of society in security, the implications of members of the clergy in pedophilia scandals, the Church's long silence on these implications and its internal management of these scandals, and finally religious pluralism and religious fundamentalism have all contributed to changing the discourse of state law on Sacramental secret. Formerly the disclosure of sacramental secrecy was subject to prosecution. Today, it is rather the retention of criminal information which is liable to incur the criminal responsibility of the confessor. This new relationship between penal responsibility and sacramental secrecy does not agree with the language of the Catholic Church, for whom sacramental secrecy must remain an absolute right subject to excommunication in case of violation. The controversy is obvious and the search for a compelling solution is imperious. How to solve the enigma of sacramental secrecy in a two-speed society that seeks to conciliate absolute transparency and human dignity: the first calling for the disclosure of information to the detriment of human dignity and the second, retention, to the detriment of the safety of the citizen. The case of sexual assaults committed against minors is the one that, currently, alarm society at the highest level. This issue of sacramental secrecy facing the new legal requirements of denunciation is common to several geographical areas, but the approaches of solutions are not the same. The search for a more conciliatory relationship between the secrecy and criminal responsibility could go through the comparison of several positive rights. The model of French law appears to be less intrusive to the right to freedom of religion of the penitent and the Catholic priest in this case. And it is in light of this law that we propose a reform of the Quebec model whose right to the protection of youth penalizes the sacramental secrecy. It is on the theories of "joint governance" whose transformative accommodation is the corollary, of "legal relevance" and pluralism of cooperation respectively developed by Ayelet Shachar, Santi Romano and Mireille Delmas-Marty, that this thesis is based on modeling a new relationship between the positive law of Quebec and canon law about what is opposed to them. It is an imperative for the Church to preserve the confidence of the penitents who present themselves to the sacrament of penance in order to avoid making the confessor a criminal agent or an informer. But the safety of children in ecclesial communities and their confidence in a Church that protects and defends them is also one. The legal aggiornamento in the Church, based on a safeguarding of the right of the offender, preservation of the right of the Church to its identity, but also and above all on strengthening the right of the victim, is a substantial contribution of the Church to the repression and the fight against the sexual abuse of children and constitutes proof of its good faith.
Koné, Moriba Alain. "La protection du consommateur dans le commerce international passé par Internet: une analyse comparée des systèmes juridiques européen, français, canadien et québécois." Thèse, 2007. http://hdl.handle.net/1866/2679.
Full textWith the exponential development of the Internet and the consequent expansion of online commerce, the fate of cyberconsumer protection has become a topic of increasing concern in the 21st century. In fact, in a virtual world where new methods and technologies are used-as are abusive clauses in unilaterally drafted contracts-a feeling of mistrust between cyberconsumer and cybermerchant is certainly setting in. National and international laws and community norms have been adopted in order to rigorously control the contractual process and to thereby re-establish consumer confidence and further Internet commerce. However, due to the frequent presence of foreign elements in on-line commercial contracts, the fundamental question which naturally arises for those who are studying the subject is whether the classic rules of private international law have become outdated by the incredibly rapid development of this type of commerce, or whether such laws are in fact adapted. One can also question whether the legal framework offered to the cyberconsumer is able to procure the same level of protection that a consumer would benefit from in cases of traditional commerce. This study aims to present certain elements of a response, first, by analyzing substantive internal law in the realm of consumer protection in the European, French, Canadian and Quebec legal systems, in order to examine areas of conflict that are likely to exist during the lifespan of this sort of contract. In the second part, this study demonstrates that the classic methods of resolving conflicts of jurisdiction and conflicts of law in private international law, while requiring certain adaptations, can nevertheless be effectively applied to the context of the Internet with the objective of protecting cyberconsumers. The results of this analysis and evaluation of the private international rules of conflict then lead to an assessment of the new measures that are required.
Books on the topic "Droit comparé français-québécois"
Mémeteau, Gérard. La responsabilité civile médicale en droit comparé français et québécois. Montréal, Qué: Centre de recherche en droit privé et comparé du Québec, 1990.
Find full textPotvin, Louise. La personne et la protection de son image: Étude comparée des droits québécois, français et de la common law anglaise. Cowansville, Qué: Éditions Y. Blais, 1991.
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