Agrégateur de flux

This post has been written by Dr Mykola Lazeranko, postdoctoral fellow at KU Leuven Law. I am most grateful for his contribution. Of note is that Mykola’s aim is not to highlight whether the Russian courts are correct in their approach; rather to document their private international law methodology.

Geert.

 

Introduction

Mid-December 2025, news outlets across Europe and beyond reported that the Central Bank of the Russian Federation had initiated proceedings against Euroclear in the Moscow Arbitration Court, seeking approximately USD 229 billion in relation to frozen Russian assets (see Guardian, Reuters, VRT news, etc.). On 17 December 2025, the court issued a ruling accepting the statement of claim for consideration and scheduled a court hearing for 16 January 2026 (see here).

On 16 January 2026, the court issued several procedural rulings. In particular, it dismissed Euroclear’s application for strike-out (formally ‘application to have the statement of claim left without consideration’), it granted Euroclear’s application to adjourn the preliminary hearing, and it granted the application of the Central Bank of the Russian Federation for the proceedings to be conducted in camera on the grounds that the case involves secreta commercii.

The next hearing is scheduled for 4 March 2026.

While the European Commission earlier dismissed the claim as ‘speculative’ and groundless, the litigation forms part of a broader pattern: since 2022, Russian courts have witnessed a steady increase in claims against Euroclear arising from sanctions-related asset freezes. By mid-January 2026, just short of 200 claims against Euroclear had been filed across Russia.

This post examines the private international law (PIL) dimension of this litigation, using the core, ‘trigger’ case of Bank Saint Petersburg v Euroclear. Its aim is to analyze how the courts grounded their reasoning to reject arguments of Euroclear that EU and Belgian law is applicable, and how it built sanctions-related case-law against Euroclear based on Russian law.

The Trigger Case: Bank “Saint-Petersburg” v. Euroclear

The Euroclear-related litigation began with case No. А40-205635/2022, filed in September 2022 before the Moscow Arbitration Court by Bank “Saint-Petersburg” PJSC.The bank sought compensation for losses it attributed to Euroclear’s blocking of funds following the imposition of EU sanctions.

In February 2023, the court of first instance granted the claim, awarding the bank USD 107,085,768.65 and EUR 488,994.50 in damages, alongside litigation costs. On appeal, the claimant withdrew the euro-denominated portion, and in May 2023, the Ninth Arbitration Court of Appeal upheld the decision for the USD portion. It also clarified that payment should be made in Russian roubles according to the exchange rate on the date of payment.

From the outset, the issue of applicable law was central. Euroclear stated that the dispute fell under EU law and Belgian law, invoking the regulatory framework governing its activities and the contractual arrangements between Euroclear and the Russian National Settlement Depository (NSD).

Consolidation of Defendants: From NSD and Euroclear to Euroclear Alone

Initially, the claim was brought jointly against Russia’s National Settlement Depository – NSD and Euroclear. From a PIL perspective, such a combination of domestic and foreign defendants could have implications for both jurisdiction and applicable law.

However, during the proceedings the claimant withdrew its claim against NSD. The court further emphasised that NSD could not be a defendant in this case because the claimant and NSD were bound by an arbitration agreement providing for dispute resolution before the Arbitration Centre at the Russian Union of Industrialists and Entrepreneurs. Consequently, the claims against NSD were left without consideration, and Euroclear remained the sole defendant.

The court made it clear that the mere involvement of a foreign party does not provide grounds to disregard an arbitration agreement. Had the claims against NSD and Euroclear been brought separately, the court noted, those would not have fallen within its jurisdiction.

PIL: First Instance

 Public Order as a Consideration

Relying on Article 1193 of the Russian Civil Code, the court noted that foreign law must yield to Russian law when the consequences of its application would have obviously been in conflict with the fundamentals of law and order (public order, ordre public) of the Russian Federation. The court stressed that when deciding whether it is necessary to apply the ordre public exception, the court should proceed not from a contradiction between the content of the foreign rule and the fundamental principles of the legal order (i.e. not from a review of the substance of foreign law), but from the unacceptability, for the forum state, of the consequences resulting from the application of the foreign law provision.

The court also stated that according to the Presidium of the Supreme Arbitration Court (informational letter No. 156 of 26 February 2013), ‘public order’ encompasses fundamental legal principles of the highest imperative authority, universality, and particular social and public significance, forming the foundation of the state’s economic, political, and legal system. Among these principles is the prohibition of actions explicitly forbidden by peremptory norms of Russian law (Art. 1192 of the Civil Code) when such actions threaten the sovereignty or security of the state.

Applying this standard, the court held that EU sanctions preventing the transfer of funds to the bank were incompatible with fundamental constitutional principles. Under Article 55(3) of the Russian Constitution, restrictions on the exercise of rights by Russian legal entities may be imposed only by federal law. Russian legislation does not compel compliance with foreign sanctions, hence, judicial enforcement of EU sanctions would contravene Russian public order.

The court stated that liability for harm in Russian law is a private-law construct, grounded in principles of fairness, proportionality, and fault. Proportionality, directly mentioned in the aforementioned informational letter No. 156 of 26 February 2013 of the Presidium of the Supreme Arbitration Court, is considered part of Russian public order.

The court further emphasised the prohibition of abuse of rights. Drawing on the Resolution of the plenum of the Russian Supreme Court of  23 June 2015, No. 25 “About application of some provisions of the Section I of part one of the Civil code of the Russian Federation by courts”, it noted that exercising a right in a manner that causes harm to others, particularly through unlawful means, constitutes abuse. Material damage, including the diminution of economic value or the need for additional expenditures, falls within this category. The court cited the ruling of the Supreme Court of the Russian Federation dated 28 November 2017, No. 309-ЭС-13269, in case No. А07-27391/2016, indicating it as a source where it is noted that the breach of the prohibition on abuse of rights constitutes violation of the principles of public order of the Russian Federation.

The court also relied on statutory and constitutional authorities concerning sanctions: the Federal Law “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States”, which identifies foreign sanctions targeting Russia as threatening territorial integrity and economic stability, and the ruling of the Constitutional Court of the Russian Federation dated 13 February 2018 No. 8-П, where the court held that a right whose exercise depends on compliance with sanctions imposed against Russia or its economic entities by any state, outside proper international legal procedures and contrary to multilateral treaties to which Russia is a party, cannot be protected by the courts.

Non-Contractual Nature of the Claim

Euroclear argued that Belgian law should govern because of the contractual arrangements with NSD. The court rejected this, noting that the claims were non-contractual in nature, arising from harm caused by Euroclear’s actions, and therefore outside the scope of any contractual choice of law. The applicable law must be determined according to the conflict-of-law rules governing obligations arising from harm.

Lex Loci Damni and Foreseeability

Article 1219 of the Civil Code provides that obligations arising from harm are governed by the law of the place where the harmful act occurred, or, if the harm occurs elsewhere, the law of the place where the damage materialised, provided the harm was foreseeable.

The court found that the damage occurred in Russia, and Euroclear knew or ought to have known that blocking the funds would harm Russian entities. Sanctions were expressly directed at Russia, and Euroclear had been informed of the impact.

The court referred to paragraph 52 of the Plenum Resolution of the Supreme Court of the Russian Federation No. 24 dated 9 July 2019, “On the Application of Private International Law Norms by Courts of the Russian Federation”, which provides that if a claim arises from harm caused by an act or other circumstance that occurred on the territory of the Russian Federation, or if the harm materialized on the territory of the Russian Federation, the court may apply Russian law to the relations between the parties.

Accordingly, the court stated that since the consequences of the harm caused by the actions (or inaction) of Euroclear occurred on the territory of the Russian Federation, and Defendant was aware of the location where the harm would materialize, the applicable law governing these relations is the law of the Russian Federation.

Closest Connection

Finally, the court applied the subsidiary rule of closest connection (Article 1186 of the Civil Code), considering that the legal relationship is most closely connected with the Russian Federation for the following reasons:

• • Bank Saint Petersburg, as a banking organization registered in the Russian Federation, is claiming damages (actual loss) in its favour to fulfill its obligations to a wide range of parties, including both individuals and legal entities;
  • The harm caused by the unjustified actions (or omissions) of Euroclear since March 2022 is substantial, affecting not only the claimant but also specific individuals and legal entities, as well as the economy of the state;
  • The issuers of the securities for which funds were not transferred to the Bank are predominantly Russian entities;
  • The agreement between the NSD and the Bank is governed by Russian law, and NSD’s obligations were not fulfilled due to Euroclear’s actions (or omissions) that were inconsistent with Russian legislation.

These factors, the court concluded, outweighed the arguments relied upon by Euroclear.

PIL: Appellate Review

 In its May 2023 judgment, the Ninth Arbitration Court of Appeal endorsed the reasoning of the first-instance court concerning the PIL, further systematising its approach.

Emphasising Articles 247–249 of the Arbitration Procedure Code and Supreme Court Plenum Resolution No. 23 (2017), the appellate court further assessed jurisdiction and connection to Russia:

• • The bank’s main activity is in Russia, oriented toward Russian clients.
  • Key evidence resides with NRD, Russia’s central depository, subject to Russian law and supervision.
  • The securities involved were issued by Russian entities, and Euroclear’s actions had a significant economic impact domestically.
  • Euroclear maintains accounts in Russia.

The court in its judgment indicated that with regard to the present case, the arbitration court of the Russian Federation has jurisdiction to hear the Bank’s claims on the basis of the following:

• • Bank “Saint-Petersburg” PJSC, as a banking institution registered in the Russian Federation, seeks recovery of losses in its own favour for the purpose of performing its obligations towards a wide range of persons, including both individuals and legal entities.
  • The claimant’s principal business activities are carried out in the territory of the Russian Federation and are oriented towards Russian individuals and legal entities.
  • The damage caused to the Bank by the unjustified actions (or omissions) of Euroclear Bank SA/NV, commencing in March 2022, is substantial and affects not only the claimant, but also its clients and the economy of the state.
  • The main evidence confirming the need to transfer funds in favour of Bank “Saint-Petersburg” PJSC is held by the NSD on the territory of the Russian Federation. NSD, as a Russian legal entity, possesses the key evidence in the present dispute.
  • The obligations arising in connection with the Eurobonds for which funds were not transferred to the Bank involve predominantly Russian issuers.
  • The agreement between NSD and the Bank is governed by Russian law, and NSD’s obligations were not performed as a result of actions (or omissions) of Euroclear Bank SA/NV that were inconsistent with Russian legislation.
  • NSD, as the party obliged to transfer funds to the Bank, is registered in the Russian Federation, holds the status of Russia’s central securities depository, and its activities are regulated by Russian law and supervised by the Central Bank of the Russian Federation.
  • Euroclear Bank SA/NV maintains bank accounts within the territory of the Russian Federation.

The appellate court stated that the court of first instance in its consideration of the case correctly established that the law applicable to the present dispute is the law of the Russian Federation, and that the arbitration court of the Russian Federation has jurisdiction to hear the Bank’s claim against Euroclear. As  indicated in its ruling, the occurrence of damage within the territory of the Russian Federation constitutes an additional basis for the jurisdiction of the Russian arbitration court.

Overall, the appellate court’s decision did not introduce new substantive arguments but, to some extent, supported and further formalised the PIL reasoning, creating a guide for the large number of Euroclear-related claims in Russia.

Conclusion

The Bank Saint Petersburg v Euroclear litigation demonstrates the Russian courts’ interpretation and application of PIL principles in a sanctions context. Key takeaways include:

1. 1. Public order (ordre public) considerations override foreign law where enforcement would conflict with fundamental constitutional or statutory principles.
   2. Non-contractual claims arising from harm are governed by the law of the place where harm occurs, rather than contractual choice-of-law clauses.
   3. Lex loci damni and foreseeability determine applicable law when harm has consequences in another state.
   4. Closest connection serves as a subsidiary test, weighing factors such as the parties’ domicile, the location of harm, and the economic and legal context.

In Euroclear-related disputes, the Russian courts have constantly rejected arguments delivered by Euroclear to apply EU and Belgian law, establishing Russian law as the governing law for sanctions-related claims, which represents the interplay between private international law and the enforcement of cross-border sanctions.

At present, the court register shows around 190 cases across the Russian Federation against Euroclear. All of these cases were initiated after the decision in Bank Saint Petersburg v Euroclear, and in the majority of them final judgments have already been rendered (as a rule, the claims against Euroclear are upheld). The reasoning supporting the jurisdiction of the Russian courts and the application of Russian law in all such cases mirrors that adopted in this ‘trigger’ case.

Mykola.

Michele Angelo Lupoi and Davide Castagno (both university of Bologna) have posted The Yearbook of the Ravenna Summer School on Cross-Border Litigation and International Arbitration 2024 Edition on SSRN. The abstract reads: This yearbook collects papers presented at the 2024 edition of the Ravenna Summer School on Cross-border litigation and international arbitration, organised by the […]

On 5 and 6 March 2026, the Faculty of Law at Lund University will host a conference entitled Collaboration in International Family Law. The event will bring together leading academics and practitioners to explore how cooperation between key actors functions in international family law, from both national and comparative perspectives. The first day (from 14 […]

Contexte. La Commission européenne a proposé la modification du règlement (UE) 2024/1689 du Parlement européen et du Conseil du 13 juin 2024 établissant des règles harmonisées concernant l’intelligence artificielle (Règlement IA ou AI Act) avant même son entrée en vigueur. Sa proposition dite « Omnibus IA » s’ajoute à l’Omnibus numérique qui suggère d’importantes modifications du RGPD.

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The recently published Part 4 of the Juridical Review for 2025 contains articles based on the International Perspectives on Scots Law seminar series held at the University of Stirling during 2023/2024. Some of these articles will be of interest to private international law aficionados:

‘The Pre-enactment Legislative Review Process in Scotland’ by Robert Brett Taylor and Adelyn L.M. Wilson (University of Strathclyde);

‘Taking the Transnational Nature of the UK Competition Appeal Tribunal Seriously: A Private International Law Perspective’ by Mihail Danov (University of Exeter);

‘The Evolution of Business and Human Rights Litigation against Multinational Companies’ by Mukarrum Ahmed (University of Lancaster);

‘Parties’ Intention and the Future Internationalisation of Scottish Arbitration – A Review of Scottish cases post 2010′ by Hong-Lin Yu (University of Stirling);

‘The Art of Persuasion: Embracing the Auld enemy and Beyond’ by Dr Mo Egan (University of Stirling).

The following information was kindly shared with us by the editors of the JLMI.

The Journal of Law, Market & Innovation (JLMI) welcomes submissions for its third issue of 2025.

The Call for Papers for this 3rd issue is devoted to Digital markets, consumer autonomy and consumer welfare.

You can find the call with all the details at the following link:

Digital markets, consumer autonomy and consumer welfare

Prospective articles should be submitted in the form of abstract (around 800 words) or draft articles to submissions.jlmi@iuse.it within 25 february 2026. The publication of the issue is set for the end of November 2026.

For further information, or for consultation on a potential submission, you can contact us by email at editors.jlmi@iuse.it.

Visit our website to read the full announcement.

The following information was kindly shared with us by De Gryuter Brill.

The Hague Academy is a renowned international institution dedicated to the study and teaching of public and private international law. Supported and recognized by the United Nations, the Academy aims to foster rigorous and impartial analysis of legal issues arising from international relations. Its courses address both theoretical and practical dimensions of international law, including legislation and case law. In principle, all courses are published in the Collected Courses of The Hague Academy of International Law in the language in which they were originally delivered. The courses on private international law that were published in 2025 are:

• Volume 451: Garcimartin, F.: Responses to a Legally Fragmented World: A Private Law Perspective (General Course of Private International Law)
• Volume 449: Esplugues, C.: New Dimensions in the Application of Foreign Law by Courts (and Arbitrators) and Non-Judicial Authorities
• Volume 446: Dickinson, A.: Natural Justice in Recognition and Enforcement of Foreign Judgments
• Volume 446: McLachlan, C.: On the Interface Between Public and Private International Law (General Course on International Law)
• Volume 445: Rodríguez Benot, A.: Le régime économique des couples en droit international privé

For a full listing, including the courses on public international law and international arbitration, please visit The Hague Academy Collected Courses Online / Recueil des cours de l’Académie de La Haye en ligne.

On 9 February 2026, the French Cour de Cassation will hold a one-day symposium titled Revisiting the international element in contracts (Revisiter l’internationalité du contrat). The event is organised by the Société de Législation Comparée, the Cour de Cassation and the academic research unit GREDEG (Côte d’Azur University), and is coordinated by Gustavo Cerqueira (Côte d’Azur […]

Veuillez mettre à jour votre lecteur RSS afin d’utiliser le lien sur cette page :

On 20 November 2025, the European Commission (EC) released a communication titled DigitalJustice@2030. It features the EU Digital Justice Strategy for 2025-2030 announced in May 2025 in a call for evidence (reported here). Building on the EU Council’s e-Justice Strategy 2024-2028 (presented here), the new EC Strategy maps the main actions to be conducted the next five […]

If you do use the blog for research or database purposes, citation would be appreciated, to the blog as a whole and /or to specific blog posts. Many have suggested I should turn the blog into a paid for, subscription service however I have resisted doing so. Proper reference to how the blog is useful to its readers, will help keeping this so.

I have given background to Limby v Dyson when I discussed the important jurisdictional decisions. Current post deals with case management issues held by Pepperall J in Limbu & Ors v Dyson Technology Ltd & Ors [2026] EWHC 38 (KB).

The judgment is crucial for the discussion of equality of arms in supply chain due diligence claims, an issue which as the judge in current case also points out, was part of the forum non considerations at the time of the jurisdictional challenge. The judge’s considerations [8] re access to justice, costs, realism viz law firms contingency fees (and a side note on the barristers in the case, who of course act as single, self-employed risk takers viz the recoverability of their time spent) are an example of realism, empathy, concern for the rule of law and appreciation of real-life impact.

A first important issue under consideration comes down to whether the judge would order the case to first proceed with lead claimants, having to prove their working conditions etc, or rather, as defendants suggested, cut to the chase (claimants’ counsel called it ‘answering the siren song) as to Dyson’s knowledge and control of the circumstances in which claimants found themselves, with factual circumstances assumed for the purpose of the liability trial. [31] ff the judge explains while he rejects the latter (incl the difficulty of any appeal judges having to hear an appeal on the basis of assumed rather than proven facts) and he distinguishes the case management in Municipio on this point. [44] ff the claim in unjust enrichment is not going to trial now, for here the judge finds it impossible to split the issues of liability for and the assessment of the extent of any unjust enrichment (the latter requiring costly forensic evidence).

Focusing on one more element of the case-management: the request, which was granted, for ‘specific’ disclosure of a number of specific documents, even prior to what is known as ‘first disclosure’. There is an asymmetry of information between the parties as to what was reported to and known by Dyson. The judge ordered disclosure of 5 specific documents (the existence of which was revealed in related libel proceedings against Channel 4 journalists).

A judgment of much note, and another round hard fought by claimants, underscoring their need for tenacity and for support by level-headed lawyers.

Geert.

EU private international law, 4th ed. 2024, Chapter 7.

 

On Tuesday, February 3, 2026, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 11:00 a.m. – 12:30 p.m. (CEST). Stellina Jolly (South Asian University) will speak, in English, about the topic

“Forging a Path for Climate Justice: Integrating Public and Private International Law in Transboundary Litigation in India”

Cross-border climate litigation, gaining traction globally, requires active engagement with private international law for effective dispute adjudication. Although Indian climate jurisprudence has not yet substantively addressed cross-border disputes, emerging trends suggest that this scenario may soon evolve. The talk analyses three plausible litigation scenarios involving Indian and foreign parties to assess the readiness of Indian private international law in addressing transboundary climate harm. Firstly, Indian plaintiffs filing cases in foreign jurisdictions against transnational corporations headquartered abroad, alleging climate-related harm caused within India; secondly, foreign plaintiffs filing cases before Indian courts for the harm caused by Indian transnational corporations in their jurisdictions; thirdly, foreign plaintiffs filing cases before Indian courts for the transboundary harm caused by Indian companies as a result of their Greenhouse gas (GHG) emissions. The talk evaluates the adequacy of Indian private international law in addressing cross-border climate cases and proposes incorporating environmental and human rights considerations in the determination of choice of law.

The presentation will be followed by open discussion. All are welcome. More information and sign-up here.

If you want to be invited to these events in the future, please write to veranstaltungen@mpipriv.de.

In a judgment of 9 September 2025 the Danish Supreme Court clarified how Danish private international law determines the applicable law in recourse claims between insurance agencies and vehicle owners after an international traffic accident. The Court confirmed that, in the absence of codified conflict-of-laws rules, the starting point is the law of the place […]

A new collective volume entitled “La circolazione dello statuto personale / La circulation du statut personnel” has recently been published by Pacini Giuridica. Edited by Gustavo Cerqueira (Nice), Nicolas Nord (Strasbourg) and Claudio Scognamiglio (Rome), the book brings together the proceedings of an international conference held on 19 January 2024 in Rome, in the prestigious Giallombardo Hall of the Italian Court of Cassation.

The conference and the resulting volume stem from a joint initiative supported by several leading institutions in the fields of private law, comparative law and private international law: the Société de législation comparée (Comparative Methodology of Civil Law Section), the Associazione Civilisti Italiani and the International Commission on Civil Status (CIEC), with the support of the of the Italian Court of Cassation and the Faculty of Law and Political Science of Nice.

The volume addresses the circulation of personal status in a broad sense, at a time when increasing mobility of persons, the continuous renewal of issues relating to personal status, and sustained legislative and judicial activity across jurisdictions make this topic more relevant than ever. Rather than focusing on a single issue, the contributors adopt a comprehensive approach encompassing civil status in cross-border situations, personal identification, family relationships, filiation, and nationality. Taken together, these areas reflect the contemporary legal conception of the person, shaped by complex family ties and by the dynamics of cross-border recognition.

With contributions from scholars and practitioners from France, Italie and Switzerland, the book offers a genuinely civil, international and comparative perspective. Its bilingual Italian-French format further enhances its accessibility and comparative value for a European private international law readership. The richness of the discussions reproduced in the volume confirms the relevance of the chosen approach and makes a significant contribution to ongoing scholarly debates on the circulation of personal status.

Further information on the book is available on the publisher’s website. 

 

English translation of fate Table of Contents:

 

Preface
Foreword Introduction
Nicolas Nord, The Circulation of Personal Status: Introductory Report

Civil Status and Cross-Border Situations

Gustavo Cerqueira, Civil Status and Borders
Francesco Salerno, The Paradigm of Substantive Values in the Extraterritorial Relevance of Personal Status
Marion Ho-Dac, Personal Status and International Cooperation: Attraction, Diversity and Obstacles

Identification of the Person

Giovanni Di Rosa, Identification of the Person: The Circulation of Surnames
Fernanda Munschy, The Cross-Border Circulation of Modified Gender Identity: From Attribution to Free Choice
Francesca Bartolini, The Circulation of a Person’s Sex: Attribution, Rectification and Autonomy

Union of Persons

Lukas Heckendorn Urscheler, The Circulation of Registered Partnerships: Tensions between Terminological Unity and Conceptual Diversity
Alessandra Spangaro, The Circulation of Registered Unions: Between Terminological Unity and Conceptual Diversity
Enrico Al Mureden, Same-Sex Marriage and Its Circulation: Between the Rights of the Couple, the Protection of the Child and the Prohibition of Surrogacy
Ilaria Pretelli and Renzo Calvigioni, Unions Celebrated Abroad: Certificates of Capacity and the Opportunities Offered by the New CIEC Convention No. 35

Filiation

Gordon Choisel, Filiation Based on Parenthood, or the Reversal of French International Public Policy
Mirzia Bianca, The Proliferation of Models of Parenthood: Reflections on De Facto Parenthood
Sylvain Bollée, Surrogacy: Spontaneous Circulation and Imposed Circulation
Roberto Senigaglia, The Circulation of Filiation Status Arising from Surrogacy Practices Established in EU and Non-EU States: The Case for a Differentiated Approach

Nationality

Hugues Fulchiron, Nationality and the Circulation of Personal Status: The Multiplication of Contemporary Issues
Sabine Corneloup, Evidentiary Difficulties and Obstacles to the Circulation of Status in Matters of Nationality

Conclusions
Liliana Rossi Carleo, The Circulation of Personal Status: Concluding Remarks

 

On 30 December 2025, Directive (EU) 2025/2647 amending Directive 2013/11/EU on alternative dispute resolution for consumer disputes and amending Directives (EU) 2015/2302, (EU) 2019/2161 and (EU) 2020/1828 following the discontinuation of the European Online Dispute Resolution Platform has been published on the Official Journal of the European Union. Directive (EU) 2025/2647 introduces important changes to […]

The latest issue of the Journal of Private International Law (Volume 21, Issue 3) features seven articles. Elena Rodríguez-Pineau, Cross-border Insolvency Avoidance Actions in the EU: A Necessary Reflection, 393-416 After 25 years, the European Union can boast of having harmonised EU cross-border insolvencies in a Regulation (recasted once). The EU is presently addressing substantive harmonisation of insolvency […]

The Directorate-General for Justice and Consumers of the European Commission has recently published a fourth edition of the Compendium of European Union legislation on judicial cooperation in civil and commercial matters. This document is extremely valuable and its updated publication is to be welcomed. In a common judicial area, marked by a tradition of written […]

The author of this post is Lydia Lundstedt, who is an Associate Professor and Senior Lecturer at Stockholm University and Linköping University. As a consequence of the free movement logic, the country of origin principle in the EU E-Commerce Directive allows providers of information society services to rely on the legislation of their country of […]

In 2025, the Court of Justice of the European Union gave some twenty rulings dealing either with legislative measures in the field of judicial cooperation in civil and commercial matters or, more generally, with issues of private international law (notably in connection with rules of EU primary law on EU citizenship or fundamental economic freedoms). […]

La gestion géorgienne des manifestations antigouvernementales pose manifestement question. Alors que la Géorgie est de nouveau pointée du doigt par de nombreuses organisations non gouvernementales pour avoir récemment condamné, le 3 septembre dernier, plus d’une dizaine de manifestants en lien avec des événements survenus à l’occasion de rassemblements antigouvernementaux, la Cour européenne des droits de l’homme a rendu un arrêt de grande chambre reconnaissant un recours injustifié à la force aux fins de la dispersion d’une manifestation au moyen de projectiles à impact cinétique devant le Parlement, à Tbilissi, en juin 2019.

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