Activity: Organizing, contributing or attending an event › Organizing or contributing to an event › Academic
On Thursday 14 October 2021 an online M-EPLI roundtable took 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. 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 brought 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.