On Thursday 14 October 2021 an online M-EPLI roundtable will take place on private international law issues relating to the recognition and enforcement of foreign (mostly US) punitive damages judgments in countries outside of Europe.
An often-heard obstacle in this regard is the public policy-exception. In a number of European countries, for example Italy, Spain and Germany, the supreme courts have rendered decisions on this matter.
Following the decision of the Italian supreme court of 2017, a conference was organised in Milan by the Department of Italian and Supranational Public Law of the University of Milan in 2018. A program of this conference, in which the organizers of this M-EPLI roundtable took part, can be found here. During the conference, the private international law question has been addressed from the perspective of several European countries.
We have decided to broaden this question and look into countries outside of Europe because extensive research into such jurisdictions has not been done yet. In this M-EPLI roundtable we bring together a group of experts who will reflect on the current position of their country (and surrounding countries). The insights gained through this research could be useful for the ongoing debate on the future of punitive damages in Europe.
We look forward to seeing you in October!
Lotte Meurkens and Cedric Vanleenhove
09.45 Cedric Vanleenhove (Ghent University / University of Liège)
Recognition of punitive damages in Europe, the status quo
10.00 Béligh Elbalti (Osaka University)
Recognition of punitive damages in Japan, Korea and Philippines
10.45 Wenliang Zhang (Renmin University of China)
Recognition of punitive damages in China
11.15 María Guadalupe Martínez Alles (IE University)
Recognition of punitive damages in Argentina and Mexico
11.45 Questions and break
12.15 Vsevolod Chernyy (Lomonosov Moscow State University)
Recognition of punitive damages in Russia
12.45 Lotte Meurkens (Maastricht University)
Punitive damages in Europe, the road ahead
13.00 Questions and concluding remarks