Views
HUK-COBURG II: A Case on Mandatory Overriding Law or Jurisdiction?
By Ross Pey, Western University, Canada
1. Introduction
In Case C-86/23 E.N.I. and Y.K.I. v HUK-COBURG-Allgemeine Versicherung AG II (‘HUK-COBURG II’), the principal issue that arose was whether a Bulgarian compensation provision may be interpreted as having mandatory effect. In suggesting that it does not, the Court required the facts to have sufficiently close links with the forum. (Hereinafter the ‘sufficient connexion test’) Ostensibly, a freestanding sufficient connexion test could be viewed as a disguised jurisdictional control of the forum rather than part of a mandatory law analysis. In doing so, parallels to renvoi and forum non conveniens are drawn. Read more
Book Review: L. d’Avout’s La Cohérence Mondiale Du Droit (Brill)
The general course in private international law delivered at the Hague Academy of International Law by Louis d’Avout during the 2022 Summer Session was published in the Academy’s Pocket Books Series (1 032 pages). Louis d’Avout is Professor at Université Paris Panthéon-Assas. In addition to his numerous scholarly works, readers of this blog may recall that his special course on “L’entreprise et les conflits internationaux de lois” was also published in the Academy’s Pocket Books Series in 2019. The general course is title « La cohérence mondiale du droit » (“The Global Coherence of Law”). The publication of a general course in private international law—particularly in the Academy’s Pocket Books Series—deserves the attention of the readers of this blog. The aim of this review is, modestly, to offer a glimpse into this important work so readers who are sufficiently francophone may be encouraged to read it directly, while those who are not are offered a brief overview of the author’s approach. Read more
Trial Supervision System No Longer Impediment in Hong Kong’s Recognition and Enforcement of Chinese Mainland Judgments
1. Introduction
For more than 20 years after the handover, Hong Kong courts had regularly noted difficulties with the ‘trial supervision system’ 
(also known as ‘retrial procedure’ 
) in the Chinese Mainland when attempting to recognise and enforce Mainland judgments under the common law, as the trial supervision system was thought to mean that these judgments fail to meet the ‘final and conclusive’ requirement. Such thinking was criticised by scholars as problematic.[1] To address the issue, statutory regimes on the reciprocal recognition and enforcement of judgments between the Chinese Mainland and Hong Kong have been implemented. More recent studies documented changes in the judicial attitude of Hong Kong courts,[2] but there was a lack of definitive rulings to clarify the legal position. This article focuses on the most recent Hong Kong cases which confirmed that the trial supervision system in the Chinese Mainland has no automatic impact on the recognition and enforcement of Mainland judgments in Hong Kong. A party alleging that the trial supervision system has affected the finality and conclusiveness of a Mainland judgment must prove the likelihood of a retrial being ordered through factual and/or expert evidence.
News
Call for Papers: 6th PIL Early Career Researchers’ Conference (9/10 April 2027, Munich)
Hot on the heels of the publication of the proceedings of the 5th PIL Early Career Researchers’ Conference, the organizers of the 6th conference have just published the Call for Papers (German version).
The conference will take place on 9 and 10 April 2027 at the Ludwig Maximilian University of Munich under the title ‘Crises in PIL – Crises of PIL’, which the organizers introduce as follows:
We are living in an age of polycrisis: war and environmental destruction are forcing thousands upon thousands to flee; growing social inequality and the concentration of economic power are undermining social cohesion; political polarization and the rise of renationalization threaten the project of European integration and international cooperation. At our conference, we aim to explore the implications of these crises for private international law (PIL). What new questions do the political, social, economic, and ecological crises of our time raise for PIL? How does PIL contribute to crisis management, or, conversely, to the exacerbation of crises? And might the discipline of PIL itself be in crisis?
The keynote speech will be given by Heinz-Peter Mansel (University of Cologne).
More information can be found on the conference website.
HCCH Monthly Update: March 2026
Membership
On 4 March 2026, Guatemala deposited its instrument of acceptance of the Statute, becoming the 93rd Member of the HCCH. More information is available here.
Conventions & Instruments
On 1 March 2026, the 2019 Judgments Convention entered into force for Albania and Montenegro. At present, 33 HCCH Members are either bound by the 2019 Judgments Convention or a Contracting Party for which the Convention has not entered into force yet (Andorra). More information is available here (for Albania) and here (for Montenegro).
On 1 March 2026, the 2005 Choice of Court Convention entered into force for Monaco. At present, 38 States and the European Union are bound by the 2005 Choice of Court Convention. More information is available here.
Meetings & Events
From 3 to 6 March 2026, the Council on General Affairs and Policy (CGAP) of the HCCH met in The Hague. The meeting was attended by 560 participants joining both in person and online. During the meeting, the Members of the HCCH reviewed progress made to date and agreed on the work programme for the year ahead, taking important decisions on work relating to possible new legislative instruments, post-Convention work, and governance matters. More information is available here.
From 9 to 11 March 2026, the Regional Workshop on Sharing Experiences on the Effective Implementation of the 1993 Adoption Convention in Africa was held in Cape Town, South Africa. More information is available here.
On 24 March 2026, the first meeting for Central Authorities on the operation of the 1965 Service, 1970 Evidence and 1980 Access to Justice Conventions was held online, hosted by the PB of the HCCH.
Publications
On 3 March 2026, the Permanent Bureau announced the publication of the HCCH 2025 Annual Report. More information is available here.
Upcoming events
Registration is open for the 14th International Forum on the electronic Apostille Programme (e-APP), which will take place in hybrid format on 12 and 13 May 2026 in Marrakesh, Morocco. The registration deadline is Friday 1 May 2026, 5.00 p.m. (CEST). More information is available here.
Vacancies
Applications are now open for three- to six-month legal internships for the period from September 2026 to February 2027. The deadline for the submission of applications is 20 April 2026. More information is available here.
These monthly updates are published by the Permanent Bureau of the Hague Conference on Private International Law (HCCH), providing an overview of the latest developments. More information and materials are available on the HCCH website.
Call for Abstracts: International Conference on Modern Problems of Private International Law, Poznan – Riga
The following announcement was shared with us by the conference organizers, Aleksandrs Fillers (Riga Graduate School of Law, Latvia), Adrian Rycerski (SWPS University in Poznan, Poland).
