McCallum v. Italy involved the extradition of a U.S. national accused of murdering her husband and the burning of his corpse in Michigan. According to a press release from the Court, At the time she filed her case, she was being detained in Rome, but at the time of the judgment, she was in detention in the U.S. In denying her request to stay her extradition, the Italian authorities referred to the U.S. appeals process, the possibility of a pardon or a commutation of her sentence by the Michigan governor as reasons counseling in favor of extradition. They also felt that there were no reasons to believe that she would be subject to inhuman or degrading treatment there. Several months later, the U.S. authorities sent a diplomatic note to Italy indicating that McCallum would be tried for the lesser offense of second degree murder, which would carry with it the possibility of parole. A new extradition order was issued by Italy, but the Court ordered that it be stayed pending these proceedings. In ultimately holding that the extradition would not violate Article 3, the Court pointed out the importance of Michigan's diplomatic note, indicating that a lesser charge would be imposed. Citing prior case law, the Court noted that “Diplomatic Notes carry a presumption of good faith and that, in extradition cases, it was appropriate that that presumption be applied to a requesting State which has a long history of respect for democracy, human rights and the rule of law, and which has longstanding extradition arrangements with Contracting States” (¶ 51, citing Harkins & Edwards v. UK , nos. 9146/07 and 32650/07 ).
{"title":"Briefly Noted","authors":"","doi":"10.1017/ilm.2023.13","DOIUrl":"https://doi.org/10.1017/ilm.2023.13","url":null,"abstract":"McCallum v. Italy involved the extradition of a U.S. national accused of murdering her husband and the burning of his corpse in Michigan. According to a press release from the Court, At the time she filed her case, she was being detained in Rome, but at the time of the judgment, she was in detention in the U.S. In denying her request to stay her extradition, the Italian authorities referred to the U.S. appeals process, the possibility of a pardon or a commutation of her sentence by the Michigan governor as reasons counseling in favor of extradition. They also felt that there were no reasons to believe that she would be subject to inhuman or degrading treatment there. Several months later, the U.S. authorities sent a diplomatic note to Italy indicating that McCallum would be tried for the lesser offense of second degree murder, which would carry with it the possibility of parole. A new extradition order was issued by Italy, but the Court ordered that it be stayed pending these proceedings. In ultimately holding that the extradition would not violate Article 3, the Court pointed out the importance of Michigan's diplomatic note, indicating that a lesser charge would be imposed. Citing prior case law, the Court noted that “Diplomatic Notes carry a presumption of good faith and that, in extradition cases, it was appropriate that that presumption be applied to a requesting State which has a long history of respect for democracy, human rights and the rule of law, and which has longstanding extradition arrangements with Contracting States” (¶ 51, citing Harkins & Edwards v. UK , nos. 9146/07 and 32650/07 ).","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"36 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135526488","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Resolution 2646 (July 28, 2022) – The Security Council underscored the important role of the United Nations “in assisting the parties to bring the Cyprus conflict and division of the island to a comprehensive and durable settlement with a sense of urgency.” It reaffirmed its relevant resolutions on Cyprus and “fully support[ed] the Secretary-General’s ongoing engagement with the sides.” The Council called on the Turkish and Turkish Cypriot leaders to urgently take a number of actions, including to “continue to reinvigorate their efforts to provide the necessary support and overall guidance to free the Technical Committees from political obstructions in their work and enable them to function effectively in coordination and cooperation on matters which have island-wide implications” and to “improve the public atmosphere for negotiation to secure a settlement, including by preparing the communities for a settlement through public messages on the way ahead, and delivering more constructive and harmonised messages.” The Council noted with regret “the ongoing lack of meaningful participation of women’s organisations and youth in the Settlement process, but welcome[d] the adoption and launch of the Action Plan on women’s full, equal and meaningful participation in the settlement process, to support and encourage engagement with civil society.” The Council furthermore “deeply regret[ted] the lack of progress on an effective mechanism for direct military contacts between the sides and the relevant involved parties, and urges flexibility and engagement by the sides and the relevant involved parties, facilitated by [the United Nations Peacekeeping Force in Cyprus] UNFICYP, to develop a suitably acceptable proposal on the establishment of such a mechanism, and its timely implementation.” The Council extended the mandate of UNFICYP until January 31, 2023.
{"title":"United Nations Security Council Resolutions","authors":"","doi":"10.1017/ilm.2023.12","DOIUrl":"https://doi.org/10.1017/ilm.2023.12","url":null,"abstract":"Resolution 2646 (July 28, 2022) – The Security Council underscored the important role of the United Nations “in assisting the parties to bring the Cyprus conflict and division of the island to a comprehensive and durable settlement with a sense of urgency.” It reaffirmed its relevant resolutions on Cyprus and “fully support[ed] the Secretary-General’s ongoing engagement with the sides.” The Council called on the Turkish and Turkish Cypriot leaders to urgently take a number of actions, including to “continue to reinvigorate their efforts to provide the necessary support and overall guidance to free the Technical Committees from political obstructions in their work and enable them to function effectively in coordination and cooperation on matters which have island-wide implications” and to “improve the public atmosphere for negotiation to secure a settlement, including by preparing the communities for a settlement through public messages on the way ahead, and delivering more constructive and harmonised messages.” The Council noted with regret “the ongoing lack of meaningful participation of women’s organisations and youth in the Settlement process, but welcome[d] the adoption and launch of the Action Plan on women’s full, equal and meaningful participation in the settlement process, to support and encourage engagement with civil society.” The Council furthermore “deeply regret[ted] the lack of progress on an effective mechanism for direct military contacts between the sides and the relevant involved parties, and urges flexibility and engagement by the sides and the relevant involved parties, facilitated by [the United Nations Peacekeeping Force in Cyprus] UNFICYP, to develop a suitably acceptable proposal on the establishment of such a mechanism, and its timely implementation.” The Council extended the mandate of UNFICYP until January 31, 2023.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"112 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132365786","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
On September 22, 2022, the Human Rights Committee (HRC) published its views in the communication of Daniel Billy et al. v. Australia, originally submitted in May 2019. Although not the first case before human rights treaty bodies on matters relevant to climate change, it is the first time the Human Rights Committee has found a state party to the International Covenant on Civil and Political Rights (ICCPR) in breach of its obligations under the ICCPR for failure to take mitigation and adaptation measures to combat the effects of climate change. In doing so, it made a number of comments on both procedural and substantive issues, which may well pave the way for future action.
{"title":"Views adopted by the Committee under Art. 5(4) of the Optional Protocol, concerning Communication No. 3624/2019 (U.N.H.R. Committee)","authors":"Maria Gavouneli","doi":"10.1017/ilm.2023.3","DOIUrl":"https://doi.org/10.1017/ilm.2023.3","url":null,"abstract":"On September 22, 2022, the Human Rights Committee (HRC) published its views in the communication of Daniel Billy et al. v. Australia, originally submitted in May 2019. Although not the first case before human rights treaty bodies on matters relevant to climate change, it is the first time the Human Rights Committee has found a state party to the International Covenant on Civil and Political Rights (ICCPR) in breach of its obligations under the ICCPR for failure to take mitigation and adaptation measures to combat the effects of climate change. In doing so, it made a number of comments on both procedural and substantive issues, which may well pave the way for future action.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"61 1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132053424","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The resolution “Territorial Integrity of Ukraine: Defending the Principles of the Charter of the United Nations” was adopted by the UN General Assembly (UNGA) on October 12, 2022, with 143 UN member states in favor, five against, thirty-five abstentions, and ten not voting. It is another important UNGA resolution on Ukraine, after the UNGA qualified as aggression Russia's invasion of Ukraine since February 24, 2022 in its resolution of 2 March 2022. That resolution had 141 states voting in favor, thus a slight increase in votes supporting Ukraine's rights under international law can be seen in the resolution at issue.
{"title":"Resolution ES-11/4 Territorial Integrity of Ukraine: Defending the Principles of the Charter of the United Nations (U.N.G.A.)","authors":"Lauri Mälksoo","doi":"10.1017/ilm.2023.9","DOIUrl":"https://doi.org/10.1017/ilm.2023.9","url":null,"abstract":"The resolution “Territorial Integrity of Ukraine: Defending the Principles of the Charter of the United Nations” was adopted by the UN General Assembly (UNGA) on October 12, 2022, with 143 UN member states in favor, five against, thirty-five abstentions, and ten not voting. It is another important UNGA resolution on Ukraine, after the UNGA qualified as aggression Russia's invasion of Ukraine since February 24, 2022 in its resolution of 2 March 2022. That resolution had 141 states voting in favor, thus a slight increase in votes supporting Ukraine's rights under international law can be seen in the resolution at issue.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"118 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122463755","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
On June 21, 2022, the Court of Justice of the European Union (CJEU), sitting as a Grand Chamber, rendered its decision in the preliminary ruling procedure C-817/19, Ligue des Droits Humains v. Council of Ministers . In its ruling, the CJEU held that the surveillance regime established by the Passenger Name Record Directive 2016/681 (PNR Directive) was compatible with the Charter of Fundamental Rights of the European Union (CFREU/EU Charter). Nevertheless, the CJEU strictly circumscribed the Directive's transposition within EU member states' domestic laws. While restricting permissible interpretations of the PNR Directive's provisions and imposing strict limitations on its scope to ensure its conformity with the EU Charter, for the first time the Court upheld an instrument of indiscriminate surveillance as compatible with EU primary law. This represents a significant development in the CJEU's case law on privacy rights, which is likely to affect the negotiation and development of future PNR agreements with third countries, as well as the development of the ePrivacy Regulation, discussions surrounding the regulation of AI, and negotiations for international instruments aiming to address serious crimes. Further, the ruling confirms the CJEU's increasing convergence with the European Court of Human Rights' (ECtHR) case law on the matter, thus inscribing national security as a legitimate exception to the general prohibition of indiscriminate bulk data collection and retention in Europe.
{"title":"Case C-817/19, Ligue des Droits Humains v. Council of Ministers (C.J.E.U.)","authors":"Sophie Duroy","doi":"10.1017/ilm.2023.8","DOIUrl":"https://doi.org/10.1017/ilm.2023.8","url":null,"abstract":"On June 21, 2022, the Court of Justice of the European Union (CJEU), sitting as a Grand Chamber, rendered its decision in the preliminary ruling procedure C-817/19, Ligue des Droits Humains v. Council of Ministers . In its ruling, the CJEU held that the surveillance regime established by the Passenger Name Record Directive 2016/681 (PNR Directive) was compatible with the Charter of Fundamental Rights of the European Union (CFREU/EU Charter). Nevertheless, the CJEU strictly circumscribed the Directive's transposition within EU member states' domestic laws. While restricting permissible interpretations of the PNR Directive's provisions and imposing strict limitations on its scope to ensure its conformity with the EU Charter, for the first time the Court upheld an instrument of indiscriminate surveillance as compatible with EU primary law. This represents a significant development in the CJEU's case law on privacy rights, which is likely to affect the negotiation and development of future PNR agreements with third countries, as well as the development of the ePrivacy Regulation, discussions surrounding the regulation of AI, and negotiations for international instruments aiming to address serious crimes. Further, the ruling confirms the CJEU's increasing convergence with the European Court of Human Rights' (ECtHR) case law on the matter, thus inscribing national security as a legitimate exception to the general prohibition of indiscriminate bulk data collection and retention in Europe.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"151 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135748164","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
On June 21, 2022, the Court of Justice of the European Union (CJEU), sitting as a Grand Chamber, rendered its decision in the preliminary ruling procedure C-817/19, Ligue des Droits Humains v. Council of Ministers. In its ruling, the CJEU held that the surveillance regime established by the Passenger Name Record Directive 2016/681 (PNR Directive) was compatible with the Charter of Fundamental Rights of the European Union (CFREU/EU Charter). Nevertheless, the CJEU strictly circumscribed the Directive's transposition within EU member states' domestic laws. While restricting permissible interpretations of the PNR Directive's provisions and imposing strict limitations on its scope to ensure its conformity with the EU Charter, for the first time the Court upheld an instrument of indiscriminate surveillance as compatible with EU primary law. This represents a significant development in the CJEU's case law on privacy rights, which is likely to affect the negotiation and development of future PNR agreements with third countries, as well as the development of the ePrivacy Regulation, discussions surrounding the regulation of AI, and negotiations for international instruments aiming to address serious crimes. Further, the ruling confirms the CJEU's increasing convergence with the European Court of Human Rights' (ECtHR) case law on the matter, thus inscribing national security as a legitimate exception to the general prohibition of indiscriminate bulk data collection and retention in Europe.
{"title":"Case C-817/19, Ligue des Droits Humains v. Council of Ministers (C.J.E.U.)","authors":"Sophie Duroy","doi":"10.1017/ilm.2023.08","DOIUrl":"https://doi.org/10.1017/ilm.2023.08","url":null,"abstract":"On June 21, 2022, the Court of Justice of the European Union (CJEU), sitting as a Grand Chamber, rendered its decision in the preliminary ruling procedure C-817/19, Ligue des Droits Humains v. Council of Ministers. In its ruling, the CJEU held that the surveillance regime established by the Passenger Name Record Directive 2016/681 (PNR Directive) was compatible with the Charter of Fundamental Rights of the European Union (CFREU/EU Charter). Nevertheless, the CJEU strictly circumscribed the Directive's transposition within EU member states' domestic laws. While restricting permissible interpretations of the PNR Directive's provisions and imposing strict limitations on its scope to ensure its conformity with the EU Charter, for the first time the Court upheld an instrument of indiscriminate surveillance as compatible with EU primary law. This represents a significant development in the CJEU's case law on privacy rights, which is likely to affect the negotiation and development of future PNR agreements with third countries, as well as the development of the ePrivacy Regulation, discussions surrounding the regulation of AI, and negotiations for international instruments aiming to address serious crimes. Further, the ruling confirms the CJEU's increasing convergence with the European Court of Human Rights' (ECtHR) case law on the matter, thus inscribing national security as a legitimate exception to the general prohibition of indiscriminate bulk data collection and retention in Europe.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"11 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"123343374","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
On June 10, 2022, by consensus, the International Labour Conference (ILC) adopted a resolution amending the Declaration on Fundamental Principles and Rights at Work to encompass “a safe and healthy working environment.” Under this Declaration, adopted in 1998, all 187 member states of the International Labour Organization (ILO) have an obligation, arising from their membership, “to respect, promote and realize … the principles concerning the fundamental rights” that are the subject of ILO Conventions recognized as fundamental. The other four fundamental categories are freedom of association and the effective recognition of the right to collective bargaining, the elimination of all forms of forced or compulsory labor, the effective abolition of child labor, and the elimination of discrimination in respect of employment and occupation.
{"title":"2022 Amendments to the ILO Declaration on Fundamental Principles and Rights at Work","authors":"A. Trebilcock","doi":"10.1017/ilm.2023.7","DOIUrl":"https://doi.org/10.1017/ilm.2023.7","url":null,"abstract":"On June 10, 2022, by consensus, the International Labour Conference (ILC) adopted a resolution amending the Declaration on Fundamental Principles and Rights at Work to encompass “a safe and healthy working environment.” Under this Declaration, adopted in 1998, all 187 member states of the International Labour Organization (ILO) have an obligation, arising from their membership, “to respect, promote and realize … the principles concerning the fundamental rights” that are the subject of ILO Conventions recognized as fundamental. The other four fundamental categories are freedom of association and the effective recognition of the right to collective bargaining, the elimination of all forms of forced or compulsory labor, the effective abolition of child labor, and the elimination of discrimination in respect of employment and occupation.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"135 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122678340","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
China's foreign judgment recognition and enforcement regime has been the least developed part of its private international law, as opposed to jurisdiction and choice of law. The regime remained almost immutable over three decades from the 1980s, even though the civil procedure law that established it went through several revisions. Under the present Civil Procedure Law (CPL), the regime consists of rules regarding qualified applicants, legal bases, and refusal grounds for recognition and enforcement. According to these rules, the creditor of an effective foreign judgment or the foreign court rendering it may seek its recognition and enforcement before a Chinese court. The Chinese court shall review the application based on international treaties China has concluded or acceded to, or the principle of reciprocity. If the effective foreign judgment has not proven to contravene the fundamental principles of Chinese laws and the sovereignty, security, and public social interests of the state, it will be recognized and enforced; otherwise, it will not receive recognition and enforcement.
{"title":"Conference Summary of the Symposium on Foreign-Related Commercial and Maritime Trials of Courts Nationwide (Sup. People's Ct. China)","authors":"Yong Gan","doi":"10.1017/ilm.2023.4","DOIUrl":"https://doi.org/10.1017/ilm.2023.4","url":null,"abstract":"China's foreign judgment recognition and enforcement regime has been the least developed part of its private international law, as opposed to jurisdiction and choice of law. The regime remained almost immutable over three decades from the 1980s, even though the civil procedure law that established it went through several revisions. Under the present Civil Procedure Law (CPL), the regime consists of rules regarding qualified applicants, legal bases, and refusal grounds for recognition and enforcement. According to these rules, the creditor of an effective foreign judgment or the foreign court rendering it may seek its recognition and enforcement before a Chinese court. The Chinese court shall review the application based on international treaties China has concluded or acceded to, or the principle of reciprocity. If the effective foreign judgment has not proven to contravene the fundamental principles of Chinese laws and the sovereignty, security, and public social interests of the state, it will be recognized and enforced; otherwise, it will not receive recognition and enforcement.","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"45 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-03-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131058479","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
On July 25, 2022, the first Article 25 Arbitration Appeal award was issued. The Article 25 mechanism is being used while Appellate Body appointments are still blocked . The substance of the case concerned a dispute between the European Union and Turkey regarding a localization requirement whereby Turkey required foreign producers to commit to localize in Turkey their production of certain pharmaceutical products and where producers did not commit to doing so, relevant products were no longer reimbursed by the Turkish Social Security Institution. Ultimately, the arbitral panel found that the localization requirement was not justifiable under GATT (and consequently that the panel below had not erred in its judgment).
{"title":"Briefly Noted","authors":"","doi":"10.1017/ilm.2023.1","DOIUrl":"https://doi.org/10.1017/ilm.2023.1","url":null,"abstract":"On July 25, 2022, the first Article 25 Arbitration Appeal award was issued. The Article 25 mechanism is being used while Appellate Body appointments are still blocked . The substance of the case concerned a dispute between the European Union and Turkey regarding a localization requirement whereby Turkey required foreign producers to commit to localize in Turkey their production of certain pharmaceutical products and where producers did not commit to doing so, relevant products were no longer reimbursed by the Turkish Social Security Institution. Ultimately, the arbitral panel found that the localization requirement was not justifiable under GATT (and consequently that the panel below had not erred in its judgment).","PeriodicalId":212220,"journal":{"name":"International Legal Materials","volume":"63 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-02-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"134940685","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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