Duffy v Centraal Beheer Achmea. Interim payments qalified as procedural, not...
Update 23 February 2021 see Gilles Cuniberti here on a related issue of the application of the lex causae to interim proceedings, with the French Supreme Court reversing decades of case-law to hold...
View ArticleJohnson v Berentzen. The doubtful Pandya conclusions on service as lex causae...
Cressida Mawdesley-Thomas has overview of the facts and issues in Johnson v Berentzen & Anor [2021] EWHC 1042 (QB) here. Stacey J essentially confirms the conclusions of Tipples J in Pandya. The...
View ArticleSuppipat v Siam Bank. Unsatisfactory discussion of legal advice privilege and...
Suppipat & Ors v Siam Commercial Bank Public Company Ltd & Ors [2022] EWHC 381 (Comm) repeats (and indeed refers to) the inadequate discussion of applicable law and privilege in PJSC Tatneft v...
View ArticleNicholls v Mapfre. Yet again, and divergently so, on Spanish interest rates...
Nicholls & Anor v Mapfre Espana Compania de Seguros y Reaseguros SA [2023] EWHC 1031 (KB) yet again discusses the evidence and procedure carve-out in Rome II and its relationship with A15 Rome II...
View ArticleThe PIFFS v Al Wazzan litigation continues with disclosure order viz...
I reported earlier on the jurisdictional issues in a case where PIFSS brings claims for sums totalling in the region of US$874 million, arising from the alleged corruption between 1994 and 2014 of its...
View ArticleMcCarthy v Jones. On lex fori, lex voluntatis, equitable remedies and Spanish...
McCarthy v Jones & Anor [2023] EWCA Civ 589 is an appeal from Jones & Anor v McCarthy [2022] EWHC 2186 (Ch) which I had not reported on the blog probably because I had not seen it (it happens...
View ArticleX v Y (monies owed on real estate transaction). Court Den Haag leaves hanging...
X v Y (*grumbles his usual grumble about anonymisation*) ECLI:NL:GHDHA:2023:1759 is an interesting judgment discussing, yet not determining, the extent of Rome I’s Article 18’s ‘burden of proof’...
View ArticleLott et al v Citroen et al (Dieselgate). An interesting judgment on...
In Lott & Ors v PSA Automobiles SA & Ors [2023] EWHC 2568 (KB), Fontaine SM deals with an evidential /discovery issue in one of the dieselgate cases, where the car manufacturers intend to...
View ArticleNest Investments v Deloitte. The DIFC Court of Appeal on foreign law is fact...
Nest Investments Holding Lebanon S.A.L. & Ors v Deloitte & Touche (M.E.) & Anor [2023] DIFC CA 012 is of comparative conflict of laws interest on the issue of foreign and domestic law...
View ArticleMaceió victims v Braskem. Rotterdam court refuses application for Article 34...
Update 1 August 2024 the court has now also held on the merits. Appeal is likely, however the judgment was already declared enforceable: Braskem’s objections [5.62] that this forces it into an...
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