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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
German Society of International Law: Short Conference on “Law without Borders? Extraterritorial Regulation and Unilateral Action” (Munich, 11/12 June 2026)
The German Society of International Law (GSIL) will be hosting a ‘short conference’ dedicated to “Law without Borders? Extraterritorial Regulation and Unilateral Action” in Munich on 11 and 12 June 2026. While its academic events are usually limited to members of the Society, this particular event has been opened up for other academics working on questions of international law, including doctoral candidates. Participation is free of charge.
The programme can be found here; registration is possible here.
Dark Spots of the European Succession Regulation: A Decade of Its Application
On 15 May 2026, the Faculty of Law of the University of Coimbra will host the conference “Dark Spots of the European Succession Regulation: A Decade of Its Application” (“Pontos Negros do Regulamento Europeu das Sucessões: Uma década da sua aplicação”).
The conference aims to discuss some of the most controversial, uncertain and unresolved issues arising from the first decade of application of the European Succession Regulation (Regulation (EU) No 650/2012). The programme brings together scholars and practitioners from different jurisdictions and legal traditions, combining presentations in Portuguese, Spanish and English.
The event will take place at the Legal Institute’s premises of the Faculty of Law of the University of Coimbra.
The full programme and further information are available here.
Call for Papers: 2nd Riga Private International Law Conference: ‘European Private International Law: An Era of Reforms’
The following call was kindly shared with us by Aleksandrs Fillers (Riga Graduate School of Law).
This year is marked by growing discussions about revisions of the core EU private international law documents. The 2nd edition of the Riga Private International Law Conference aims to reflect on the possible changes to be encouraged and those to be discouraged. This year the conference will mostly focus on three core ‘general’ EU private international law instruments: Brussels Ibis Regulation, Rome I and Rome II Regulations.
The conference is organized by the Riga Graduate School of Law and will be held online via Zoom on 22 June 2026. Please submit abstracts of no more than 300 words to associate professor Dr. Aleksandrs Fillers (aleksandrs.fillers@rgsl.edu.lv) by 1 June 2026. We will notify you about the acceptance of papers by 5 June 2026.
Selected articles will be published in the Baltic Yearbook of International Law (indexed in Scopus).