Acceding to the Hague Choice of Court Convention is one of the unilateral steps the United Kingdom is planning to take to partially close the gap that will open in the field of judicial cooperation when the Brussels Regulation falls away upon Brexit.
We have regularly covered the Hague Convention of Choice of Court Agreements on this blog. From a German, and indeed from a European perspective, a major breakthrough in terms of practical relevance of the Convention would be the ratification of the convention by the United States, given that there currently is no treaty in place between Germany and its biggest non-European trading partner that deals with recognition of judgments. Ted Folkman on his blog lettersblogatory.com is probably the best source for coverage of the Convention’s road towards ratification in the United States. This is what Ted has to Report: Continue reading
Following the first successful IBA Litigation Committee Conference on Private International in Milan in 2014, the Litigation Committee is presenting the second edition, again in Milan. This year’s topic is The Hague Convention on Choice of Court Agreements: New Perspectives in International Commercial Dispute Resolution (click here for the full programme). Continue reading
We have covered the Hague Convention on Choice of Court Agreements on several occasions (see, most recently, here and here). Now, the Convention is about to get a new party, and Patrick Dahm, a partner in my firm’s Singapore office, has the details:
On April 14, 2016, the Singapore Parliament has passed the Choice of Court Agreements Bill, about a year after Singapore signed the Convention on March 2015. The Bill is pending presidential assent and publication in the Government Gazette, which will bring it into force.
With this, the number of Convention parties will increase to three nominally, but effectively to 28: prior to Singapore, the Convention had been signed and ratified by Mexico and the European Union (spanning the EU itself and its members except Denmark). Signatories which have yet to ratify the Convention are the USA and Ukraine. Continue reading