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‘Paramount clause’ in a bill of lading as choice of law under Rome I – the Supreme Court of the Netherlands in Airgas USA v Universal Africa Lines
In Airgas USA v Universal Africa Lines (7/11/2025, ECLI:NL:HR:2025:1665), the Supreme Court of the Netherlands considered the interpretation of a so-called ‘Paramount clause’ in a bill of lading. Such clauses commonly signpost which rules govern the international carriage of goods by sea. The Court addressed such clause as a choice of law and held that article 3(1) of the Rome I Regulation does not preclude the parties from agreeing on such clause. Read more
“Without Regard to Principles of Conflict of Laws”
It is common to see some variation of the phrase “without regard to conflict of laws principles” appear at the end of a choice-of-law clause. Here are some examples:
“This Agreement shall be governed by and construed in accordance with the laws of the Republic of China, without regard to its principles concerning conflicts of laws.”
“This Agreement and all acts and transactions pursuant hereto and the rights and obligations of the parties hereto shall be governed, construed and interpreted in accordance with the laws of the State of Delaware, without giving effect to principles of conflicts of law.”
“This Note is being delivered in and shall be construed in accordance with the laws of the State of New York, without regard to the conflict of laws provisions thereof.”
Although this phrase is common, its purpose and origin are poorly understood. In 2020, I published an article, A Short History of the Choice of Law Clause, that attempted to demystify these issues.
Court-to-court referrals and reciprocity between Chinese and Singapore courts
By Catherine Shen, Asian Business Law Institute
In 2023 Su 05 Xie Wai Ren No. 8 dated March 14, 2025, the Suzhou Intermediate People’s Court of Jiangsu Province in China (Suzhou Court) recognized and enforced civil judgment HC/S194/2022 under file number HC/JUD47/2023 by the Supreme Court of Singapore (Singapore Judgment). The judgment by the Suzhou Court (Suzhou Judgment) was announced in September 2025 by the Supreme People’s Court of China (SPC) as among the fifth batch of Belt and Road Initiative (BRI) model cases. Read more
News
Private International Law Festival 2026: The End of the Rule-Based International Order? – Implications for Private International Law
Edinburg Law School and Max Planck Institute for Comparative and International Private Law organize a Private International Law Festival, to take place in Edinburgh 24-25 September 2026. Save the date!
And submit a proposal of up to 500 words, together with a short bio/s in the same word document, to law.events@ed.ac.uk by 10 April 2026 with the email subject clearly marked “Proposal PIL Festival_ Surname/s”. Selected speakers will be informed in May 2026.
More information about the event and the call for papers below.
EAPIL Conference in Geneva (18-20 June 2026): Early bird registration ends on 15 March!
As report earlier on this blog, the third bi-annual conference of the European Association of Private International Law (EAPIL) will take place in Geneva, Switzerland, from 18 to 20 June 2026. Under the title “Shaping the Future of Private International Law in Europe – Putting Together the Pieces & Filling Gaps”, the conference will address structural developments, unresolved issues, and emerging challenges in European private international law. The program is available on the conference’s website.
Early bird registration will close on 15 March 2026. You are welcome to register using this link.
EAPIL is looking forward to seeing you in Geneva!
Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 2/2026: Abstracts
The latest issue of the „Praxis des Internationalen Privat- und Verfahrensrechts“ (IPRax) features the following articles: