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The 2019 Hague Judgments Convention Applied by Analogy in the Dutch Supreme Court
Written by Birgit van Houtert, Assistant Professor of Private International Law at Maastricht University
On 1 September 2023, the 2019 Hague Judgments Convention (HJC) entered into force. Currently, this Convention only applies in the relationship between EU-Member States and Ukraine. Uruguay has also ratified the HJC on 1 September 2023 (see status table). The value of the HJC has been criticised by Haimo Schack inter alia, for its limited scope of application. However, the HJC can be valuable even beyond its scope as this blog will illustrate by the ruling of the Dutch Supreme Court on 29 September 2023, ECLI:NL:HR:2023:1265.
Which Law Governs Subject Matter Arbitrability in International Commercial Disputes?
Written by Kamakshi Puri[1]
Arbitrability is a manifestation of public policy of a state. Each state under its national laws is empowered to restrict or limit the matters that can be referred to and resolved by arbitration. There is no international consensus on the matters that are arbitrable. Arbitrability is therefore one of the issues where contractual and jurisdictional natures of international commercial arbitration meet head on.
Choice of law rules and statutory interpretation in the Ruby Princess Case in Australia
Written by Seung Chan Rhee and Alan Zheng
Suppose a company sells tickets for cruises to/from Australia. The passengers hail from Australia, and other countries. The contracts contain an exclusive foreign jurisdiction clause nominating a non-Australian jurisdiction. The company is incorporated in Bermuda. Cruises are only temporarily in Australian territorial waters.
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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.