Law applicable to legal actions mortis causa : notes de lege lata and de lege ferenda

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The subject of the paper is an analysis of the law applicable to legal actions mortis causa. Currently, the rules of law governing this matter are included both in a national law (Private International Law of 1965) as well as in international agreements (the Hague Convention of 5 October 1961 on the Conflicts of Laws Relating to the Form of Testamentary Dispositions and several bilateral agreements to which the Republic of Poland is a party). In the next part the paper shows the relevant conflict rules, which are included in the design acts: the draft of the new Polish Private International Law and the Proposal for a Regulation of the European Parliament and of the Co-uncil on jurisdiction, applicable law, recognition and enforcement of decisions and authentic instruments in matters of successions and on the introduction of European Certificate of Inheritance.