The Civil Legal Protection of One’s Image Right: A Comparative Study between Jordan, France, and Egypt

Murad Mahmoud Shnikat


Laws are still incapable to protect personality rights. They are also incapable to provide an effective legal framework for protecting such rights. The same applies to one’s rights to privacy, especially image right. Protecting the latter right is necessary due to the recent technological development in the field of photography. Protecting one’s image right is also necessary due to the availability of various means that can be used for infringing this right. Having such a variety led to the rise of legal problems and issues. Hence, the present study aimed to explore the civil legal protection of one’s image right under the Jordanian, French, and Egyptian laws.  It was found that one’s image right is protected by the general provision set in article 48 of the Jordanian civil law. The latter article deals with personality rights in general. However, the Jordanian legislator must adopt the same approach adopted by the French legislator. That is represented in adjusting article 48 of the Jordanian civil law to protect the image right as an independent right. That must be done due to the significance of the latter right.

Keywords: Image right, personality rights, privacy rights.

DOI: 10.7176/JLPG/82-17

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