Table of contents

1. Possible attitudes of the national Legislator with respect to cases with extraneous elements - 2. References of private international law and international civil procedural law - 3. Efficiency of the system conditioned by a substantial equivalence of the respective guiding principles - 4. Material coordination and between the different legal systems - 5. Differences in the treatment of cases with elements of extraneousness: the case of marriage - 6. Conflicts between secular legal systems and systems with a Catholic confessional inspiration: irrelevance for one of juridically perfect cases for the other systems - 7. Conduct of the conflict not in terms of "validity-invalidity" but in terms of "juridical existence-non-existence" - 8. Different consequences arising in the different systems - 9. Conflicts between the systems of secularized States and the system of the Catholic Church Roman - 10. a) Juridical non-existence of civil marriage, as such, for the legal system of the Church - 11. b) Juridical non-existence of religious marriage, as such, for secularized legal systems - 12. Consequent need for a double celebration or a double judicial intervention - 13. Conflicts between secularized state systems and strictly Catholic confessional system systems - 14. a) Strictly confessional systems: juridical irrelevance of civil marriage contracted in secularized systems - 15. b) Secularized systems: possible indirect juridical relevance of Catholic religious marriage - 16. Possible indirect relevance of the canonical system: both for the form and for the substance - 17. Possible indirect relevance of ecclesiastical sentences - 18. Recourse to the limit of international public order: its so-called "permissive" function - 19. Consequent unilateral characterization of the conflict - 20. Other reasons given to explain the irreducibility of the conflict - 21. Conflict of qualifications referring to the same "marriage" - 22. Reduction of the form of Catholic religious marriage as an element of substance - 23. Limits of international public order - 24. Possible mixed legislative situations - 25. Competition of opposing attitudes in distinct sectors of the same legal system - 26. The Italian legal system