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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
Registration open: Australasian Association of Private International Law Conference, Sydney, 16-17 April 2026
Registrations for the 2026 AAPrIL Conference, to be held on 16 and 17 Apriil 2026, are now open!
VENUE: Ashurst Lawyers
Level 8, 39 Martin Place
Sydney, New South Wales 2000
AUSTRALIA
PANELS AND SESSIONS:
- Jurisdiction
- Private International Law and Digitalisation
- Regional and International Cooperation
- Arbitration
- Applicable Law
Attendance at conference sessions can be used for CPD; you will need to check local requirements.
REGISTRATION FEES:
If you are coming for both days, please select Friday.
Non-member 2 days: $160
Non-member 1 day: $90
AAPrIL member 2 days: $120
AAPrIL member 1 day: $70
Student: Free to attend the conference only
Conference dinner: $110 for dinner and a selection of drinks
REGISTRATION INCLUDES:
Access to all conference sessions
Morning tea and coffee, morning teas and lunches
Access to purchase a conference dinner ticket at an additional cost of $110
ELI-Webinar “Enhancing Child Protection” (Int’l Filiation Law)
As already announced in another post, there will be a Webinar organized by the European Law Institute (ELI) on March 12 to present and discuss the Project Report of the ELI Project “Enhancing Child Protection: Private International Law on Filiation and the European Commission’s Proposal COM/2022/695 final”
Call for Papers: 11th Journal of Private International Law Conference (Zurich, 1–3 April 2027)
The following Call for Papers has been kindly shared with us by Christiane von Bary (University of Zurich):
Following the 20th Anniversary Conference in London (2025), we are pleased to announce that the Journal of Private International Law will be holding its 11th Conference at the University of Zurich from 1 to 3 April 2027.
We are now inviting the submission of paper proposals for the conference. Please submit an abstract if you would like to make a presentation at the conference and you are willing to produce a final paper that you will submit for publication in the Journal. Abstracts should be up to 500 words in length and should clearly state the name(s) and affiliation(s) of the author(s). Participants are also welcome to propose collective panels. If the proposal is for a panel, it should include the names and affiliations of all proposed participants.
Presentations can be on any subject matter that falls within the scope of the Journal and can be offered by people at any stage of their career, including postgraduate students and practitioners. Presentation at the conference will depend on whether your abstract is selected by the Editors of the Journal (Professor Jonathan Harris KC, King’s College, London and Professor Paul Beaumont FRSE, University of Stirling) and the conference organisers (Professors Tanja Domej and Christiane von Bary, University of Zurich). The subsequent article should be submitted to either of the editors of the Journal before the end of 2027. Publication in the Journal will be subject to the usual system of peer review.
The Conference will be held at the University of Zurich. There will be a mixture of plenary and parallel panel sessions. Speakers will not be expected to pay a conference fee but will be expected to pay for their own expenses in relation to their attendance at the conference in Zurich. Non-speakers will be expected to pay a conference fee. A conference dinner will be held on Friday (2 April 2027), at additional cost and with limited places. Details about registration, the conference dinner and options for accommodation will be made available on the conference webpage: https://t.uzh.ch/1WV.
Please send your proposal to the following e-mail address by Tuesday, 30 June 2026:
We look forward to receiving your proposals, and to welcoming you to Zurich in April 2027!