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Colonialism and German PIL (2) – German and European Structures and Values

This post is part of a series regarding Colonialism and the general structure of (German) Private International Law, based on a presentation I gave in spring 2023. See the introduction

The Convergence of Judicial Rules between Mainland China and Hong Kong has Reached a Higher Level

By Du Tao* and Jingwei Qiu**

With the increasingly close personnel exchanges and deepening economic cooperation between Mainland China and Hong Kong, the number and types of legal disputes between the two regions have also increased. Against the backdrop of adhering to the “One Country, Two Systems” principle and the Basic Law of Hong Kong, the judicial and legal professions of the two regions have worked closely together and finally signed “the Arrangement on Reciprocal Recognition and Enforcement of Judgments in Civil and Commercial Matters by the Courts of the Mainland and of the Hong Kong Special Administrative Region (hereinafter referred to as “REJ Arrangement”) in January 2019, which will come into effect in January 2024. REJ Arrangement aims to establish an institutional arrangement for the courts of the Mainland and the Hong Kong Special Administrative Region to recognize and enforce judgments in civil and commercial cases, achieve the “circulation” of judgments in civil and commercial cases, reduce the burden of repeated litigation, and save judicial resources in the two regions.

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Colonialism and German PIL (1) – Colonial Structures in Traditional PIL

This post is the first of a series regarding Colonialism and the general structure of (German) Private International Law, based on a presentation I gave in spring 2023. See the introduction here.

As mentioned in the introduction, this series does not intent to automatically pass judgment on a norm or method influenced by colonialism as inherently negative (I emphasise this because my experience shows that the impression quickly arises). Instead, the aim is to reveal these influences and to initiate a first engagement with and awareness of this topic and to stimulate a discussion and reflection.

The first category, to be discussed today, relates to the (sometimes unconscious) implementation and later continuation of the colonial structure in PIL – now and then.

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News

The Conflicts Vineyard: In the Footsteps of Symeonides

It is a real pleasure to share a new essay by Professor Symeon C. Symeonides, written on the occasion of his retirement after fifty remarkable years in the field of conflict of laws. The essay, eloquently titled Reflections from Fifty Years in the Conflicts Vineyard, was presented as part of a symposium held in his honor in May 2024 at Willamette University College of Law, and sponsored by the AALS Section on Conflict of Laws. Read more

CoL.net Virtual Roundtable on the Commission’s Brussels Ia Report

In light of the Commission’s report on the Brussels Ia Regulation (first discussed here by Xandra Kramer), ConflictofLaws.net will be hosting an ad-hoc virtual roundtable

on Tuesday, 8 July 2025, 12pm–1.30pm (CEST).

The conversation will focus on the report published by the Commission on 2 June and its implications for a possible future reform of the Regulation.

The event will feature the following panellists:

Andrew Dickinson
University of Oxford

Stefano Dominelli
University of Genoa

Pietro Franzina
Catholic University of the Sacred Heart, Milan

Thalia Kruger
University of Antwerp

Tobias Lutzi
University of Augsburg

Everyone interested is warmly invited to join via this Zoom link.

Bridging Legal Systems: A Comparative-Empirical Study on the European Account Preservation Order by Dr. Carlos Santaló Goris

Warmest congratulations to Dr. Carlos Santaló Goris on the publication of his book, The Application of the European Account Preservation Order in Germany, Luxembourg and Spain. A Comparative-Empirical Analysis (Nomos, 2025).

This scholarly work offers a timely and much-needed exploration of the European Account Preservation Order (EAPO), the first cross-border civil interim measure at EU level. Conceived to enable the provisional attachment of debtors’ bank accounts across Member States, the EAPO aspires to procedural uniformity. Yet, as this study so lucidly demonstrates, its application remains deeply embedded in national procedural systems, giving rise to significant divergences and legal complexity.

With admirable clarity, analytical depth, and empirical rigour, Dr. Santaló Goris leads the reader through this intricate legal terrain. By examining, in particular, the operation of the EAPO in three distinct jurisdictions – Germany, Luxembourg, and Spain – his manuscript illustrates the practical challenges posed by procedural fragmentation while offering valuable guidance for navigating the instrument across legal systems.

This manuscript stands out as a thoughtful and impactful contribution to the field of European civil procedure. What distinguishes it most is its remarkable ability to bridge legal theory and judicial practice. Through a combination of comparative analysis, stakeholder perspectives, and data-driven insights, it offers a comprehensive and balanced account of how the European Account Preservation Order operates in practice, making it an indispensable resource for scholars, practitioners, and policymakers alike.

Congratulations, Carlos, on this well-deserved accomplishment!

More information on this book is available here.

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