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Mutual Trust and the Dark Horse of Civil Justice

  • Eva STORSKRUBB (a1)


How to understand and deal with the principle of mutual trust, its emanations, interpretations, and imperatives has in recent years become one of the central and most critical issues in the development of the Area of Freedom Security and Justice (AFSJ). Civil justice may be the dark horse with respect to mutual trust among the policy areas of the AFSJ in the sense that it may show useful but hitherto hidden possibilities and have an un-tipped winning strategy. In particular, the balancing safeguards in legislation, the importance of which have been confirmed in case law, are important to ensure the fundamental right to a fair trial. However, that does not mean that mutual trust does not pose challenges in the context of civil justice. Hence, it remains important to focus on how—normatively, and by which regulatory means—to support mutual trust as well as how to balance, and perhaps limit, its implementation in order to enhance its legitimacy. In addition, the recent pressures towards harmonisation need to be carefully analysed.

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1 Title IV TFEU and in particular Article 81. In the context of my Marie Curie fellowship project 2014–16, I have previously addressed aspects of mutual trust in ‘Mutual Recognition as a Governance Strategy for Civil Justice?’ in B Hess et al (eds), EU Civil Justice – Current Issues and Future Outlook (Hart Publishing, 2016), ‘Mutual Trust and the Limits of Abolishing Exequatur in Civil Justice’ in D Gerard and E Brouwer (eds), Mapping Mutual Trust: Understanding and Informing the Role of Mutual Trust in EU Law (EUI Working Paper, MWP No. 2016/13), and ‘Tillit mellan rättssystemen i EU: Det civilrättsliga perspektivet’ in A Bakardjieva Engelbrekt et al, Tilliten i EU vid ett vägskäl (Santérus, 2017). The latter publication will also be published in English as ‘Mutual Trust in Civil Justice Cooperation in the EU’ in a forthcoming publication: A Michalski et al (eds), Trust in the European Union in Challenging Times (Palgrave, 2018). This contribution brings together these works and aims to deepen the analysis as well as to take into account the most recent developments.

2 Note though that ‘civil justice’ can be held to encompass also further and broader civil procedural developments in the EU such as the procedural rules for consumer or competition matters, see Storskrubb, ECivil Justice – Constitutional and Regulatory Issues Revisited’ in M Fletcher et al (eds), The EU as an Area of Freedom, Security and Justice (Routledge, 2017).

3 See inter alia in this volume Douglas-Scott, S, ‘The EU’s Area of Freedom, Security and Justice: A Lack of Fundamental Rights, Mutual Trust and Democracy?’ (2009) 11 Cambridge Yearbook of European Legal Studies 53 , and Mancano, L, ‘The Right to Liberty in European Union Law and Mutual Recognition in Criminal Matters’ (2016) 18 Cambridge Yearbook of European Legal Studies 215 .

4 I will not deal with the issue of whether or not there is a constitutional dimension, see D Gerard, ‘Mutual Trust as Constitutionalism’ in Gerard and Brouwer, note 1 above, pp 69–70, 75–78.

5 Craig, P and de Búrca, G, EU Law – Text, Cases and Materials, 6 th ed (Oxford University Press, 2015) p 622 .

6 See Whytock, C, ‘Faith and Scepticism in Private International Law: Trust, Governance, Politics, and Foreign Judgments’ (2014) Erasmus Law Review 113 , comparing the political choices in the EU and the USA.

7 Prechal, S, ‘Mutual Trust before the Court of Justice of the European Union’ (2017) 2(1) European Papers 75 , p 78.

8 Nicolaïdis, K, ‘Trusting the Poles? Constructing Europe through Mutual Recognition’ (2007) 14(5) Journal of European Public Policy 682 , p 685.

9 Chalmers, D et al, European Union Law, 3 rd ed (Cambridge University Press, 2014) p 777 and sources mentioned therein.

10 However, mutual trust has older roots in civil justice that relate to the case law of the Court on the jurisdiction rules, see Storskrubb, Tillit mellan rättssystemen, note 1 above, pp 192–194. In particular these roots relate to the lis pendens provision in the Brussels Convention of 1968. See further Kramer, XE, ‘Cross-Border Enforcement and the Brussels I-Bis Regulation. Towards A New Balance between Mutual Trust and National Control over Fundamental Rights’ (2013) 60(3) Netherlands International Law Review 343, pp 364367 . See also Blobel, F and Späth, P, ‘The Tale of Multilateral Trust and the European Law of Civil Procedure’ (2005) 30 European Law Review 528, pp 531534 . Another string of case law relates to anti-suit injunctions in connection with the jurisdiction rules of the Brussels regime, see Storskrubb, E, ‘ “Gazprom” OAO v Lietuvos Respublika: A Victory for Arbitration’ (2016) 41(4) European Law Review 578, pp 582589 . A further context is choice of law rules, see Weller, M, ‘Mutual Trust: In Search of the Future of European Union Private International Law’ (2015) 11(1) Journal of Private International Law 64, pp 7581 . See further Weller, M, ‘Mutual Trust within Judicial Cooperation in Civil Matters: A Normative Cornerstone – a Factual Chimera – a Constitutional Challenge’ (2017) 35 Nederlands International Privaatrecht 1, pp. 46 for the pre-history of mutual trust.

11 Cambien, N, ‘Mutual Recognition and Mutual Trust in the Internal Market’ (2017) 2(1) European Papers 93, p 99 .

12 Gerard and Brouwer, note 1 above, p 1. For an early start to the debate see Cramér, P, ‘Reflections on the Roles of Mutual Trust in EU Law’ in M Dougan and S Currie (eds), 50 Years of the European Treaties: Looking Back and Thinking Forward (Hart Publishing, 2009) p 43 . For a general overview of emanations of mutual recognition cross policy areas see Roth, W-H, ‘Mutual Recognition’ in P Koutrakos and J Snell (eds), Research Handbook on the Law of the EU’s Internal Market (Edward Elgar, 2017).

13 Council of the European Union, 1–16 October 1999, Conclusions of the Presidency (SN 200/1/99 REV 1).

14 Art 67(4) TFEU. See also Art 81(1) TFEU.

15 [2001] OJ C 12/1, p 1.

16 The Convention [1972] OJ L299/32 was replaced by the Brussels I Regulation, Regulation (EC) No 44/2001 [2001] OJ L 12/1, which has been replaced and repealed by its so called recast, Regulation (EU) No 1215/2012 [2012] OJ L 351/1.

17 Programme, note 15 above, p 2.

18 Ibid p 5.

19 Andersson, T, ‘Harmonization and Mutual Recognition: How to Handle Mutual Distrust’ in M Andenas et al, Enforcement Agency Practice in Europe (British Institute of International and Comparative Law, 2005) p 247 .

20 P Ortolani, ‘The Two Faces of Mutual Trust’ (not yet published).

21 Briggs, A, ‘The Principle of Comity in Private International Law’ (2011) 354 Recueil des Cours – Collected Courses of the Hague Academy of International Law 69, pp 9192 , Paul, JR, ‘The Transformation of International Comity’ (2008) 71 Duke Law and Contemporary Problems 19, pp 1920 .

22 Paul, ibid, pp 21–38. See also Briggs, ibid, pp 91–92.

23 Paul, ibid. See also Weller (2015), note 10 above, pp 69–71, on the development of recognition of foreign judgments and the tools for retaining control in traditional bilateral or multilateral private international law cooperation.

24 Whytock, note 6 above, pp 113–114. He distinguishes between internal and external private international law.

25 [1972] OJ L 299/32.

26 Régie nationale des usines Renault SA v Maxicar SpA and Orazio Formento, C-38/98, EU:C:2000:225, paras 29–33.

27 P v Q, C-455/15 PPU, EU:C:2015:763, paras 34–53 and in particular para 35.

28 See Weller (2017), note 10 above, pp 9–10, arguing that it would be more convincing if a manifest error of law by a court in one Member State could be considered contrary to the public policy of another Member State at the stage of enforcement. One might disagree, however, particularly in a case such as P v Q where the jurisdiction decision in question was not appealed in the original Member State, see para 28 of the ruling.

29 Under the system of the Regulation, recognition and enforcement are two separate concepts. Recognition entails that a judgment can be directly invoked before the authorities of another Member State without any special procedure of recognition being required. However, for enforcement, a separate procedure has formerly been required under the Regulation. The grounds for refusal are the same for both. When the term mutual recognition of judgments is used to denote a regulatory method, the term is used in a more generic manner and both concepts are included.

30 Guidelines 2015–19 for the AFSJ, EUCO 79/14, 2 June 2014, para 11.

31 See note 16 above.

32 Regulations (EC) No 805/2004, [2004] OJ L 143/15; (EC) No 1896/2006, [2006] OJ L 399/1; (EC) No 861/2007, [2007] OJ L 199/1; and (EU) No 655/2014, [2014] OJ L 189/59.

33 M Linton, ‘Abolition of Exequatur, All in the Name of Mutual Trust!’ in Hess et al, note 1 above, p 272. See also Frackowiak-Adamska, A, ‘Time for a European “Full Faith and Credit Clause”’ (2015) 52(1) Common Market Law Review 191, pp 200202 .

34 See inter alia the Enforcement Order Regulation, note 32 above, Rec 18.

35 Regulations (EC) No 2201/2003, [2001] OJ L 12/1; (EC) No 4/2009, [2009] OJ L 7/1; (EU) No 650/2012, [2012] OJ L 201/107. Note that Regulations (EU) No 1103/2006, [2006] OJ L 183/1, and (EU) No 1104/2006, [2006] OJ L 183/30 on matrimonial property regimes and property regimes of registered partnerships have not yet entered into force and will be applicable only to the participating Member States.

36 See Linton, note 33 above, pp 273–275 for a table of all civil justice measures. Also, the Property Regulations, note 35 above, include an exequatur procedure modelled on ‘old’ Brussels Regulation (EU) No 44/2001, note 16 above.

37 Linton, note 33 above, pp 264–272, provides a review of the varied mechanisms and schemes in the measures. See also Frackowiak-Adamska, note 33 above, pp 194–199, who identifies three different models, and V Lazić, ‘Multiple Faces of Mutual Recognition: Unity and Diversity in Regulating Enforcement of Judgments in the European Union’ in Fletcher et al, note 2 above, pp 342–346.

38 See Green Paper on the review of Council Regulation (EC) 44/2001, COM(2009) 175, and Commission Proposal, COM(2010) 748. See also inter alia XE Kramer, note 10 above, pp 352–354, for a brief review of the proposal and the significant criticism thereof from numerous commentators.

39 Kramer, note 10 above, p 347.

40 Ibid pp 367–370 for a review of the new provisions. See also Linton, note 33 above, calling the new proceedings a ‘hybrid’ scheme that removes the formal part of exequatur but retains the control-function in the Member State of enforcement. See further Storskrubb, note 2 above, calling the result a ‘reshuffle’ rather than removal of exequatur.

41 A7-320/2012.

42 There is a considerable doctrinal discourse on mutual trust in the context of criminal justice and immigration. For recent contributions, see inter alia the contributions in European Papers 3/2016 and 1/2017.

43 Prechal, note 7 above, pp 87–90.

44 N.S. and Others, C-411/10 and C493/10, EU:C:2011:865.

45 Ibid para 83.

46 V Mitsilegas, ‘Conceptualising Mutual Trust in the European Criminal Law: The Evolving Relationship between Legal Pluralism and Rights-Based Justice in the European Union’ in Gerard, note 1, pp 27–30. See also Radu, C-396/11, EU:C:2012:648; Melloni, C-399/11, EU:C:2013:107; Jeremy F, C168/13 PPU, EU:C:2013:358.

47 See inter alia K Lenaerts, The Principle of Mutual Recognition in the Area of Freedom, Security and Justice (Fourth Annual Sir Jeremy Lever Lecture, All Souls College, University of Oxford, 30 January 2015), pp 6–7, available at

48 Opinion pursuant to Article 218(11) TFEU Accession of the European Union to the European Convention for the Protection of Human Rights and Fundamental, Case Opinion 2/13, EU:C:2014:2454, para 191.

49 See inter alia Marguery, T, ‘Je t’aime moi non plus – The Avotiņš v. Latvia Judgment: An Answer from the ECrtHR to the CJEU’ (2017) 10(1) Review of European Administrative Law 113, p 114 , its independent constitutional nature is questioned by others however, see note 4 above.

50 See Storskrubb in Gerard, note 1 above, p 19, see also inter alia Mitsilegas, V, ‘The Limits of Mutual Trust in Europe’s Area of Freedom, Security and Justice: From Automatic Inter-State Cooperation to the Slow Emergence of the Individual’ (2012) 31(1) Yearbook of European Law 319, pp 355359 .

51 Düsterhaus, D, ‘In the Court(s) We Trust – A Procedural Solution to the Mutual Trust Dilemma’ (2017) 1 Freedom Security & Justice: European Legal Studies 26, p 27 .

52 Opinion 2/13, note 48 above, para 192. See also the defence of the Court by its president, Lenaerts, K, ‘La vie après l’avis: Exploring the Principle of Mutual (Yet Not Blind)’ (2017) 54 Common Market Law Review, in particular pp 806808 and 840 emphasising that mutual trust must be earned and should not be confused with blind trust.

53 Pál Aranyosi and Robert Căldăraru v Generalstaatsanwaltschaft Bremen, C-404/15 and C-659/15 PPU, EU:C:2016:198.

54 Marin, L, ‘“Only You”: The Emergence of a Temperate Mutual Trust in the Area of Freedom, Security and Justice and its Underpinning in the European Composite Constitutional Order’ (2017) 2(1) European Papers 141, p 144 .

55 The case has been referred to in a recent case in the context of the field of immigration C. K. and Others v Republika Slovenija, C-578/16 PPU, EU:C:2017:127. Lenaerts, note 52 above, pp 832–835, emphasizes the seminal nature of Aranyosi and Căldăraru and its application when an analogous question arises.

56 See also Lenaerts, note 47 above, p 11 et seq; M Moraru ‘Mutual Trust from the Perspective of the National Courts: A Test in Creative Legal Thinking’ in Gerard note 1 above, pp. 41–45.

57 Regulation No 805/2004, note 32 above.

58 Ibid Arts 5–6.

59 Ibid Art 10.

60 Ibid Arts 13–17, the main method of service is with confirmation of receipt. Service without confirmation of receipt is only possible if the defendant’s address is known with certainty.

61 Ibid Art 19.

62 G v Cornelius de Visser, C-292/10, EU:C:2012:142; Imtech Marine Belgium NV v Radio Hellenic SA, C-300/14, EU:C:2015:825. In addition, Pebros Servizi Srl v Aston Martin Lagonda Ltd, C-511/14, EU:C:2016:448, has confirmed that the concept of ‘uncontested’ in the Regulation is to be assessed autonomously.

63 C-292/10 paras 64–66.

64 C-300/14 para 42.

65 eco cosmetics GmbH & Co. KG and Raiffeisenbank St. Georgen reg. Gen. mbH v Virginie Laetitia Barbara Dupuy and Tetyana Bonchyk, C‑119/13 and C‑120/13, EU:C:2014:2144.

66 Ibid paras 41–42.

67 Ibid paras 43, 48–49.

68 Ibid paras 44–49.

69 Meletis Apostolides v David Charles Orams and Linda Elizabeth Orams, C-420/07, EU:C:2009:271; Trade Agency Ltd v Seramico Investments Ltd, C-619/10, EU:C:2012:531; A v B and Others, C-112/13, EU:C:2014:2195; flyLAL-Lithuanian Airlines AS v Starptautiskā lidosta Rīga VAS and Air Baltic Corporation AS, C-302/13, EU:C:2014:2319; Diageo Brands BV v Simiramida-04 EOOD, C-681/13, EU:C:2015:471; Rudolfs Meroni v Recoletos Limited, C-559/14, EU:C:2016:349.

70 Inter alia C-470/07 para 55.

71 Ibid paras 58–60, the public policy clause only applies in such cases if the error of law means that the recognition and enforcement in the Member State of enforcement would manifestly breach an essential rule of law in that jurisdiction. See also C-681/13 paras 42–50. In case C-302/13 paras 46–58, the Court also confirmed that a mere invocation of serious economic consequences does not constitute an infringement of public policy.

72 See inter alia C-681/13 paras 40, 63; C-559/14 para 47.

73 C-470/07 paras 77–79; see also C-61/10 paras 47–62 dealing with the situation if the judgment in default does not contain an assessment of the merits. See further case C-59/14 not related to a default judgment but a provisional measure and third-party rights, the Court confirms that if the third party can challenge the proceedings in the Member State of origin the enforcement cannot be refused based on public policy. See further Emmanuel Lebeck v. Janus Domino C-70/15, EU:C:2016:524 on the extraordinary review of a default judgment in domestic law.

74 C-61/10 paras 34–46.

75 C-559/14 para 44.

76 Weller (2017), note 10 above, p 8.

77 See Regulation No 2201/2003, note 35 above, Rec 12.

78 Joseba Andoni Aguirre Zarraga v Simone Pelz, C-491/10 PPU, EU:C:2010:828. See also earlier cases Doris Povse v Mauro Alpago, C-211/10 PPU, EU:C:2010:400, and Inga Rinau, C-195/08 PPU, EU:C:2008:406.

79 Zarraga v Pelz, note 78 above, paras 35–36.

80 Ibid para 22.

81 Ibid paras 44–49, 68–72.

82 See inter alia M Requejo Isidro, ‘On the Abolition of Exequatur’ in Hess et al, note 1 above, pp 298–299, and Weller (2017), note 10 above, pp 11–12.

83 COM (2016) 411 final. See also M Hazelhurst, Free Movement of Civil Judgments in the European Union and the Right to a Fair Trial (Springer, 2017) p 401.

84 (Application Number 17502/07) (ECrtHR 2016).

85 Ibid paras 121–123.

86 Ibid paras 123–124.

87 Ibid paras 105–112, the ECrtHR had first confirmed that the so called Bosphorus presumption of the ECrtHR was applicable in the case. For a discussion on the relevance of the case from this perspective see Marguery, note 49 above, pp 123–129.

88 Avotiņš v Latvia, note 84 above, paras 113–116. Note that the ruling does not here explicitly address other civil justice measures, but the general wording may come to have a much broader impact, even on other policy fields of the AFSJ. However, its remit is, in this respect, still unclear. See also Marguery note 49 above, p 134.

89 Marguery, note 49 above, pp 115, 134.

90 Biagioni, G, ‘ Avotiņš v. Latvia: The Uneasy Balance between Mutual Recognition of Judgments and Protection of Fundamental Rights’ (2016) 1(2) European Papers 579, p 590 ; Emaus, J, ‘The Interaction between Mutual Trust, Mutual Recognition and Fundamental Rights in Private International Law in Relation to the EU’s Aspirations Relating to Contractual Relations’ (2017) 2(1) European Papers 117, p 136 .

91 Weller (2017), note 10 above, p 17.

92 Under the refusal grounds in Article 45.1(a) and (b), ie public policy and default judgment where service was not effected in sufficient time and the defendant has not challenged the judgment when it was possible for it to do so.

93 See also Biagioni, note 90 above, p 594.

94 Storskrubb in Hess et al, note 1 above, and the sources mentioned therein.

95 Cambien, note 11 above, pp 107–108; Prechal, note 7 above, pp 77–78.

96 Already in the famous Cassis de Dijon case, Rewe-Zentral AG v Bundesmonopolverwaltung für Branntwein, 120/78, EU:C:1979:42. See further J Snell, ‘The Internal Market and Philosophies of Integration’ in C Barnard and S Peers (eds), European Union Law (Oxford University Press, 2014) pp 307–323.

97 Chalmers et al, note 9 above, pp. 776–779. See also Snell, note 96 above.

98 Prechal, note 7 above, p 90.

99 Cambien, note 11 above, pp 108–109.

100 Most recently in the context of financial regulation, see J Snell in Gerard, note 1 above, p 14, and Roth, note 12 above, p 460.

101 The Brussels Convention 1968 and the Rome Convention 1980 were enacted as a result of Article 220 of the EC Treaty.

102 Art 81 TFEU. In addition, there are civil justice developments today in the sector-specific policy arenas of the EU that also clearly link civil justice to the Internal Market, see Storskrubb, note 2 above.

103 Hartnell, H, ‘EUstitia: Institutionalising Justice in the European Union’ (2002) 23(1) Northwestern Journal of International Law and Business 65 . See also Blobel and Späth, note 9 above, p 546, and Storskrubb, E, Civil Procedure and EU Law – A Policy Area Uncovered (Oxford University Press, 2008) pp 233258 .

104 The Stockholm Programme – An Open and Secure Europe Serving and Protecting Citizens, OJ 2010 C 115/1.

105 The most recent Scoreboard COM(2017) 167 final. See further Dori, A, The EU Justice Scoreboard – Judicial Evaluation as a New Governance Tool (Max Planck Institute Luxemburg Working Paper, 2015).

106 Storskrubb, E, ‘Några tankar om hur EU-rättens tentakler genomtränger processrätten’ (2017) 153 (2–4) Juridisk Tidskrift Finland 360, pp 374378 .

107 Weller (2015), note 10 above, pp 95–97. See also Weller (2017), note 10 above, pp 3, 19, for an interesting proposal regarding how the Scoreboards Rule of Law decisions could be used in case law.

108 Cambien, note 11 above, p 22; Gerard, note 1 above, p 79.

109 Storskrubb in Hess et al, note 1 above. See further Blobel and Späth, note 10 above, pp 529, 540; Mitsilegas, note 50 above, pp 355–359.

110 B Hess and T Pfeiffer, Interpretation of the Public Policy Exception as Referred to in EU Instruments of Private International and Procedural Law (Study PE 453.189, 2011).

111 E. Storskrubb, ‘Ordre Public in EU Civil Justice – Lessons from Arbitration?’ in Festskrift till Gustaf Möller, JFT (2011).

112 See in this context Lenaerts, note 52 above, p 823.

113 Düsterhaus, note 51 above, pp 41–43; see also Düsterhaus, D, ‘Judicial Coherence in the Area of Freedom, Security and Justice – Squaring Mutual Trust with Effective Judicial Protection’ (2015) 8(2) Review of European Administrative Law 151, pp 180182 .

114 Kramer, XE, Procedure Matters: Construction and Deconstructivism in European Civil Procedure (Erasmus Law Lectures 33, 2013) p 27 , notes the need for empirical research.

115 Emaus, note 90 above, p 131

116 Brouwer, E, ‘Mutual Trust and Human Rights in the AFSJ: In Search of Guidelines for National Courts’ (2016) 1(3) European Papers 893, p 919 .

117 Frackowiak-Adamska, note 33 above, pp 210–216.

118 Hess, B and Kramer, XE, ‘Introduction’ in B Hess and XE Kramer (eds), From Common Rules to Best Practices in European Civil Procedure (Nomos, 2017) p 27 , calling still for more information and data on the practice of the current measures to underpin reform.

119 van den Brink, T, ‘Horizontal Federalism, Mutual Recognition and the Balance Between Harmonization, Home State Control and Host State Autonomy’ (2016) 1(3) European Papers 921, p 940 .

120 See inter alia Mitsilegas, note 46 above, pp 32–34, noting that this development is a paradigm shift. See also M Requejo Isidro, ‘Do We Need to Achieve Harmonious Cooperation? Judicial Cooperation in Criminal Matters as a Testing Field’, and M Hazelhorst, ‘Harmonious Judicial Cooperation through Harmonisation: (What) Can We Learn from Criminal Matters?’ both in Hess, B and Kramer, XE (eds), From Common Rules to Best Practices in European Civil Procedure (Nomos, 2017).

121 Note 15 above.

122 Cambien, note 11 above, p 22.

123 B Hess, ‘Mutual Recognition in the European Law of Civil Procedure’ (2012) 111 ZVglRwiss 21, pp 25, 37.

124 See Storskrubb, note 2 above, pp 352–327. See also E Storskrubb and A Wallerman, ‘Judicial Cooperation in Civil Matters – Coming of Age?’ in F Trauner and A Ripoll Servent (eds), The Routledge Handbook of Justice and Home Affairs Research (2018) pp 208–211. For recent contributions to the debate see contributions in Hess, B and Kramer, XE (eds), From Common Rules to Best Practices in European Civil Procedure (Nomos, 2017), particularly, amongst others, the chapters by Caponi, van Rhee, Whytoch, von Hein, and Cuniberti.

126 Resolution 4 July 2017 (2015/2084 INL) with underlying Report of its Committee on Legal Affairs, 6 June 2017 (PE 593.974).

127 Ibid Resolution paras 14–20, Report p 34.

128 Ibid Report p 33. See also Storskrubb note 2 above, on this complexity and constitutional inconsistency.

129 See Vernadaki, Z, ‘Civil Procedure Harmonization in the EU: Unravelling the Policy Considerations’ (2013) 9(2) Journal of Contemporary European Research 298, pp 308310 .

130 The author participates in the project led by the ELI and Unidroit and therefore is aware of the apparent bias in promoting model rules rather than centralized integration. However, the intention is not to promote any specific model as such but to promote a mix of methods.



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