Özet:

The article presents the issue of the free movement of persons in the European Union in the field of same-sex marriage rights, taking into account comparative elements. The research presents provisions of the European Union, as well as internal regulations in force in France, Ireland and Poland. The article discusses the approach to the analysed issue at the level of EU regulations and internal regulations of the examined Member States. Moreover, the interaction between EU and national regulations is an important research point. Besides the article shows case variants concerning the recognition of same-sex relationships due to the legal and ideological conditions in the analysed countries Also, the article analyses the impact and importance of the Court of Justice of the European Union and the European Court of Human Rights for the studied topic. In addition, the study takes into consideration the impact of constitutional provisions on the legalization of homosexual couples in the analysed countries. The article is divided into parts covering the following issues: free movement of persons in the European Union, the right to family reunification of European Union citizens, relations between European Union law and the internal law of the Member States, recognition of same-sex marriages in France, Ireland and Poland, and summary. The opinions of A. Tryfonidou, H. Verschueren, P. Tulea and M. Bell were included in the study due to their importance to the research are.

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