公共秩序保留是国际私法的基本制度之一,被当作一种排除外国法适用的手段。它是指依法院地国的冲突规则本应该适用某一外国法,而因其适用会危及法院地国的重大社会或公共利益、法律与道德的基本原则,即可排除其适用的一种保留制度。关于公共秩序保留,存在广义论和狭义论两种观点。其 Retention of public order is one of the basic systems of private international law and is regarded as a means of excluding the application of foreign law. It means that the rules of the State in accordance with the laws of the State should have applied a foreign law and its application could be ruled out as a reservation that would jeopardize the fundamental social, public interest, law and morality of the forum State system. With regard to the reservation of public order, there are two kinds of views: general theory and narrow theory. its