一、公共秩序保留概述公共秩序保留(公共政策)是国际私法的一种特殊制度,其基本含义是指一国法院依其冲突规范本应适用外国法时,因其适用会与法院地国家的重大利益、基本政策、道德的基本原则相抵触因而排除该外国法的适用。此外,在国际民商事司法协助领域中,公共秩序保留还指,如果民商事司法协助事项与被请求国的公共秩序相抵触,则被请求国有权 I. General Description of Public Order Retention Public order reservation (public policy) is a special system of private international law. Its basic meaning is that when a country’s courts should have applied foreign law in accordance with its conflict of laws provisions, its application would be different from that of the countries Major interests, basic policies and morals, thus ruled out the application of the foreign law. In addition, in the field of judicial assistance for international civil and commercial affairs, the reservation of public order also means that if the judicial assistance matters for civil and commercial affairs contravene the public order of the requested State, the requested State has the right