Protective clauses in private international law: problems of correlation and application

In the article, the authors examined the issues of the correlation of super-imper.tive norms (rules of direct application) and the public policy clause, establishing the relationship between the two protective clauses. The problems associated with the absence in the Russian legislation of the list of norms of direct application, as well as the criteria for their determination, are highlighted. The problem of differentiation of imperative norms of civil and international private law is investigated. The concepts of positive and negative public reservations are considered, their differences and key features of their application are determined. Based on the results of the scientific and comparative legal analysis, it was concluded that the norms of domestic legislation regarding the application of protective clauses in the field of international private law relations require further development and improvement.