公共秩序保留作为限制和排除外国法适用的一项国际私法中的重要制度,在对外国法的适用和外国法院判决的承认与执行等问题上一直发挥着重要的作用,但在国际上还没有也不可能有统一的适用标准。本文将对各国有关公共秩序的理论和司法实践进行比较从而对我国有关公共秩序的立法提出建议。 As an important system in the international private law that restricts and eliminates the application of foreign law, reservation of public order has always played an important role in the application of foreign law and the recognition and enforcement of foreign court judgments. However, there is still no internationally accepted It is also impossible to have a uniform applicable standard. This article will compare the theories and judicial practices of various countries on public order so as to make suggestions on our country’s legislation on public order.