Report from mediation webinar

We are delighted to deliver you a report from our webinar on “Mediation: an effective tool for commercial and family disputes Singapore Convention” that took place on January 28 this year. This successful event gathered speakers and participants from more than 15 countries.Lots of questions raised during the event, very positive feedback sent after the webinar showed us how much such events are needed in time of limited access to justice. Raising cross-border dispute resolution cases makes Singapore Convention on Mediation a very important tool for global universe of trade and commercial relations, it allows the parties to easily enforce the terms of the settlement agreements reached as a result of mediation in different jurisdictions. Continue reading Report from mediation webinar

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Today (03.03.2021) and Tomorrow (04.03.2021) - human rights panels on Turkey

Our friends from Turkey Litigation Support Project invite you for two online discussion panels:

1.March 3, 2021 at 16.00 (CET) – first panel on Turkey’s State of Emergency Inquiry Commission: A Means to Delay Justice? – registration link: … Continue reading Today (03.03.2021) and Tomorrow (04.03.2021) – human rights panels on Turkey

AEA-EAL3 marca 2021

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AEA-EAL letter to Minister of Justice of Turkey

Today, before the Diyarbakir 10th Heavy Penal Court, a hearing in the case concerning Tahir Elci’s killing is taking place. Despite of declarations from high officials, both the investigation and the trial in Court raise serious doubts on its transpa… Continue reading AEA-EAL letter to Minister of Justice of Turkey

AEA-EAL3 marca 2021

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Report from mediation webinar

We are delighted to deliver you a report from our webinar on “Mediation: an effective tool for commercial and family disputes Singapore Convention” that took place on January 28 this year. This successful event gathered speakers and participants from more than 15 countries.Lots of questions raised during the event, very positive feedback sent after the webinar showed us how much such events are needed in time of limited access to justice. Raising cross-border dispute resolution cases makes Singapore Convention on Mediation a very important tool for global universe of trade and commercial relations, it allows the parties to easily enforce the terms of the settlement agreements reached as a result of mediation in different jurisdictions. Continue reading Report from mediation webinar

AEA-EAL21 lutego 202121 lutego 2021

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Webinar on European Arrest Warrant

Cracow Bar Association is inviting for a free webinar on European Arrest Warrant that is taking place on Thursday, February 18, 2021 at 18.00 on Zoom.

Cracow Bar Association is organizing an international on-line conference on the European coo… Continue reading Webinar on European Arrest Warrant

AEA-EAL17 lutego 202117 lutego 2021

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European Presidents Conference in Vienna

One of the biggest legal events took place on 12.02.2021 – European Presidents Conference. For almost 50 years leaders of European Bars, Law Societies and international organisations of lawyers have been gathering in the beautiful city of Vienna to discuss crucial issues for justice and legal profession. It is the biggest European meeting of leaders of the profession organised traditionally by the Federal Austrian Bar.
In 2018 our President Maria Ślązak was one of main speakers delivering presentation on “Self-regulation or heteronomy – lawyers’ independence in danger?”. This year’s conference is devoted to “Rule of law and democracy – closing the gap between policy and practice” with keynote speaker Shirin Ebadi – Nobel Peace Prize laureate (2003)…. Continue reading European Presidents Conference in Vienna

AEA-EAL3 lutego 202121 lutego 2021

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Call for tenders - Council of Europe

Dear Colleagues and Friends,

The Council of Europe is looking for providers of international consultancy services in the following areas: independence of the judiciary; internal organisation of the judiciary, and the functioning of judicial self-g… Continue reading Call for tenders – Council of Europe

AEA-EAL3 lutego 2021

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Opening of the Legal Year in Hong Kong

The Opening of the Legal Year organized each January is a very long tradition of Hong Kong Law Society In the past it always was a huge ceremony gathering judicial and governmental officials, representatives of legal profession as well as distinguished guests from abroad. Continue reading Opening of the Legal Year in Hong Kong

AEA-EAL20 stycznia 202120 stycznia 2021

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Webinar on Mediation - info and free registration

Dear Friends,

We are delighted to invite you for our first event in this year – Mediation – an Effective Tool for Commercial and Family Disputes, Singapoore Convention, which will take place on January 28, 2021 on Zoom platform. This very practical event is free for all participants. Our speakers are experienced legal practitioners – mediators representing various countries and areas of practice.

Please read the below information, program/ agenda and register on aea-eal.eu ! Continue reading Webinar on Mediation – info and free registration

AEA-EAL19 stycznia 20213 lutego 2021

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Starsze wpisy

European courts:

ECHR judgment in the case of Schweizerische Radio- und Fernsehgesellschaft and publisuisse SA v. Switzerland (application no. 41723/14), December 22, 2020

Obliging a national public-service broadcaster to run a commercial that concerned the public interest did not breach its freedom of expression. In today’s Chamber judgment (1) in the case of Schweizerische Radio- und Fernsehgesellschaft and publisuisse SA v. Switzerland (application no. 41723/14) the European Court of Human Rights held, unanimously, that there had been: no violation of Article 10 (freedom of expression) of the European Convention on Human Rights. The two applicant companies in this case complained about the obligation imposed on them to run a commercial which, in their view, was damaging to their reputation. The first applicant company is a nation-wide public-service television and radio broadcaster, and the second applicant operated as an advertising sales company until its activities were taken over by another firm in 2016. The Court held that the obligation imposed on the applicant companies to run the disputed commercial did not amount to a disproportionate interference with their right to freedom of expression, and that it had therefore been “necessary in a democratic society”. The Court noted, among other findings, that the interference with the applicant companies’ freedom of expression was provided for by Article 35, paragraph 2, of the Federal Constitution, which states that any person who performs a task on behalf of the State is required to respect fundamental rights and to contribute to implementing them. In this connection, it noted that the advertisement in question fell outside the regular commercial context inciting the public to purchase a particular product. The commercial formed part of a multi-media campaign by which the association Verein gegen Tierfabriken, active in the fields of animal and consumer protection, was seeking to raise awareness about its website and disseminate information about animal protection. In the Court’s view, this was an aspect which concerned a debate of general interest. It reiterated that, in view of its particular position in the Swiss media landscape, the first applicant company wasrequired to accept critical opinions and to provide an outlet for them on its broadcasting channels, even if this involved information or ideas that offended, shocked or disturbed. Such were the demands of pluralism, tolerance and broadmindedness, without which there was no democratic society. In addition, it had been obvious to television viewers that the commercial represented the opinion of a third party. It was admittedly presented in a very provocative manner, but was clearly a commercial that was unrelated to the programming offered by the first applicant company. Principal facts The first applicant, Schweizerische Radio- und Fernsehgesellschaft (SSR), is a private-law association which provides nation-wide public-service radio and television broadcasts on the basis of a licence issued to it by the Swiss Confederation. The second applicant, publisuisse, was an advertising sales company in which SSR held a 99.8% stake. In 2016 the firm Admeira SA took over the latter’s activities, and it was removed from the companies register in the same year. In September 2011 Verein gegen Tierfabriken, an association which is active in the areas of animal and consumer protection, booked advertising space through the second applicant, with a view to broadcasting a commercial that it had produced. For seven seconds, the commercial displayed the association’s logo and website address, and the text “What the other media do not mention” (Was andere Medien totschweigen). The website’s address and the text were read out by an off-screen voice. This first version of the commercial was broadcast 18 times over the period from 23 to 31 December 2011. In the meantime, in November 2011 the association asked the second applicant to run a modified version of the commercial, in which the initial text had been replaced by the following message: “What Swiss Television does not mention” (Was das Schweizer Fernsehen totschweigt). Authorisation to broadcast this amended version of the advertisement was refused, on the grounds that it was damaging to commercial interests and image (geschäfts- und imageschädigend) as set out in the second applicant’s general terms and conditions. In February 2012 the association filed a complaint with the Independent Radio and Television Appeal Board (AIEP) against the first applicant, alleging that the refusal to broadcast the amended version of the commercial amounted to a form of censure. AIEP rejected that complaint. The association subsequently applied to the Second Public-Law Division of the Federal Supreme Court, which found in its favour in November 2013. The judgment was notified to the applicant companies in December 2013. The Federal Supreme Court held, among other points, that the refusal to broadcast the contested commercial amounted to a restriction on the association’s right to freedom of information, even if the second applicant company’s general terms and conditions included an exclusion clause with regard to programmes which were damaging to its commercial interests or image. It also found that the disputed commercial did not correspond to one of the categories of programmesfor which the Federal Radio and Television Act prohibited broadcasting, and that the first applicant company had also failed to show that the commercial represented an illegal interference with its personality rights or the principle of fair competition. The Federal Supreme Court considered that the commercial was admittedly unusual in that it attacked the first applicant company directly, but that a mere fear that it could damage the latter’s reputation was not sufficient to justify a refusal to broadcast it, since freedom of expression allowed, inter alia, criticism not only of public authorities, but also of individuals or private companies which were performing a task on behalf of the State. Complaints Relying on Article 10 (freedom of expression) of the Convention, the applicant companies complained about having been obliged to broadcast a commercial, which, in their view, was damaging to their reputation. The application was lodged with the European Court of Human Rights on 28 May 2014. Decision of the Court Article 10 (freedom of expression) The Court considered that the obligation to broadcast the disputed commercial amounted to an “interference by a public authority” in the applicant companies’ right to freedom of expression. As […]
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ECHR judgment in the case Usmanov v. Russia (application no. 43936/18), December 22, 2020

Revoking Russian citizenship and expelling to Tajikistan breached the European Convention. The case Usmanov v. Russia (application no. 43936/18) concerned a national of Tajikstan’s complaint about decisions to revoke his Russian citizenship and remove him from Russian territory. Mr Usmanov was granted Russian citizenship in 2008, but it was revoked ten years later when the authorities discovered that he had omitted the names of his brothers and sisters in his application. The decision to expel him had been taken after he refused to leave the country. In today’s Chamber judgment (1) in the case the European Court of Human Rights held, unanimously, that there had been: violations of Article 8 (right to respect for private and family life) of the European Convention on Human Rights as concerned both the revocation of the applicant’s Russian citizenship and the decision to expel him from Russian territory. Overall, the Court considered that the authorities’ decisions in the applicant’s case had been overly formalistic, failing to duly balance the interests at stake. In particular, they had not shown why the applicant’s failure to submit information about some of his siblings had been so grave that it was justified to deprive him of his Russian citizenship so many years after he had obtained it. Nor had they taken into account the fact that he had been living in Russia for a considerable period of time with a Russian national, with whom he had four children, and that during his stay he had not committed any offences. The Court also decided to continue to indicate to the Russian Government under Rule 39 of the Rules of Court not to expel the applicant until such time as this judgment became final or until further notice. Principal facts The applicant, Bakhtiyer Kasymzhanovich Usmanov, is a national of Tajikistan who was born in 1977. Mr Usmanov moved to Russia in 2007, together with his wife and two children. He and his wife had two more children afterwards. In 2008 he successfully applied for Russian citizenship. However, ten years later his citizenship was revoked because he had omitted some information (the names of his brothers and sisters) in his application. The domestic authorities dismissed his arguments that the missing information was not important and that he had strong ties with Russia. As a result, he was left without any valid identity documents. In April 2018 the Federal Security Service decided to issue a 35-year ban on his entering Russia because he posed a threat to national security. He was supposed to leave the country before 17 August 2018. He was arrested in November 2018 and placed in a temporary detention centre for foreigners for failing to comply with the order for him to leave the country. The courts ordered his forcible removal from Russia. He challenged the entry ban and his administrative removal in the courts, in vain. The courts ruled in particular that the entry ban had been issued by the competent authority and that, in any case, his family could follow him or stay in Russia and receive financial support from abroad. Furthermore, the courts found no evidence that Mr Usmanov’s removal would breach the European Convention. Mr Usmanov’s removal was stayed in December 2018 pending the proceedings before the European Court, following its granting his request for interim measures under Rule 39 of the Rules of Court. He has since unsuccessfully appealed against his detention. Complaints Relying on Article 8 (right to respect for private and family life), the applicant alleged that, in the decisions to revoke his Russian nationality and exclude him from Russia, the authorities had failed to duly take into account his family situation or to explain why he had posed a threat to national security. The application was lodged with the European Court of Human Rights on 11 September 2018. Decision of the Court Firstly, the Court found that revoking the applicant’s citizenship had interfered with his rights under Article 8 of the Convention. He had been deprived of any legal status in Russia and left without any valid identity documents. The Court noted in particular that Russian citizens had to prove their identity unusually often in their everyday life, from buying a train ticket to more crucial needs such as finding employment or receiving medical care. The revocation of the applicant’s citizenship had moreover been a precondition for the decisions to impose the entry ban and to remove him from the State. The Government agreed that there had been an interference with the applicant’s rights, but argued that the legislative rules had not left any discretion to the authorities in situations where a person had omitted information in their application for Russian citizenship. After it had been established that the information submitted by the applicant had been incomplete, the authorities had therefore had no choice but to annul the decision granting him Russian citizenship, irrespective of the time elapsed since the obtaining of citizenship, the strength of his ties with Russia, his family situation or other important factors. The Court found that such an approach had been excessively formalistic. It had been fostered by the legal framework, as in force at the time, and had resulted in a failure to give the applicant adequate protection against arbitrary interference. The Government had not therefore shown why the applicant’s failure to submit information about some of his siblings had been of such gravity that it had been justified to deprive him of his Russian citizenship many years after he had obtained it. Indeed, the Court found that revoking the applicant’s citizenship for such an omission, without the authorities carrying out any kind of balancing exercise, had been grossly disproportionate. The Court therefore concluded that there had been a violation of Article 8 of the Convention on account of the applicant’s Russian citizenship being revoked. Similarly, neither in the proceedings concerning the ban on entering Russia nor in the proceedings concerning administrative removal had the domestic courts duly balanced the interests at stake. Overall, […]
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ECHR judgment in the case of M.L. v. Norway (application no. 64639/16), December 22, 2020

Shortcomings in decision-making process to remove a mother’s parental authority and allow adoption of her daughter. In today’s Chamber judgment (1) in the case of M.L. v. Norway (application no. 64639/16) concerning childcare the European Court of Human Rights held, unanimously, that there had been: a violation of Article 8 (right to respect for private and family life) of the European Convention on Human Rights The case concerned the domestic authorities’ decisions to remove a mother’s parental authority and authorise her daughter’s adoption by her foster parents. The Court found in particular that the reasons for the authorities’ actions reflected the fact that insufficient importance had been attached to ensuring that placement in care be temporary and that insufficient regard had been paid to the positive duty to take measures to preserve family bonds to the extent reasonably feasible. Principal facts The applicant, Ms M.L., is a Norwegian national who was born in 1975. When the applicant’s daughter was born, in April 2011, the child welfare services arranged for Ms M.L. to stay at a family centre, given concerns about her mental health. The centre found that she had major difficulties looking after her baby and was uncooperative with staff; the child welfare services decided to place her daughter in care on an emergency basis when she was nine days old. Those services then applied to the County Social Welfare Board requesting that the child be placed in a foster home. In September 2011 the Board heard the parties and eight witnesses, concluding that Ms M.L. was capable of looking after the child on a practical but not emotional level. The Board considered that the foster care would be long-term and granted her the right to contact with her daughter four times per year, for two hours each time. Ms M.L. unsuccessfully challenged the decisions on emergency and foster care in court. Ultimately in June 2015 the Board, comprised of a lawyer qualified to act as a professional judge, a psychologist and a layperson, decided to remove the mother’s parental authority and authorise adoption. The Board heard several witnesses over two days, and the mother was present and represented by counsel. It concluded that adoption would be in the child’s best interest. The mother appealed to the courts and a hearing was held in December 2015. The District Court, sitting as a bench of a similar composition as the Board, carried out a fresh examination of the case over a meeting of several days, during which the applicant was given the opportunity to present her arguments again. The court essentially agreed with the Board, ruling that it was most likely that Ms M.L. would permanently be incapable of providing appropriate care for her daughter, given her poor cognitive functioning, and that it would be in the best interests of her daughter, who was sensitive and vulnerable and strongly attached to her foster parents, to have her care situation clarified. In 2016 Ms M.L. was refused leave to appeal by the High Court, and the Supreme Court then dismissed her appeal against that decision. Complaints Relying on Article 8 (right to respect for private and family life) of the European Convention on Human Rights, the applicant complained about the domestic authorities’ decisions to remove her parental authority and authorise her daughter’s adoption by her foster parents. The application was lodged with the European Court of Human Rights on 27 October 2016. Decision of the Court The Court considered that the authorities’ decisions concerning the applicant’s parental responsibilities in respect of her daughter and, ultimately, her daughter’s adoption by her foster parents had interfered with the applicant’s right to respect of her family life, that they had been in accordance with the law and that they had pursued a legitimate aim. It had to examine, therefore, whether the measures had been necessary in a democratic society. In regard to the County Social Welfare Board’s and the District Court’s respective decision-making processes, the Court considered that these had been comprehensive and that Ms M.L. had been afforded the requisite protection of her interests and had been fully able to present her case. The Court was also satisfied that the authorities had conducted an in-depth examination of the factors relevant to the case. Turning to the question of whether the domestic authorities had provided relevant and sufficient reasons for the impugned measures, the Court noted that it had to place those decisions in context, having regard to the earlier proceedings and decisions in the light of the case as a whole. As the District Court’s judgment had been the final judgment on the merits, the Court centred its examination on that verdict. In the Court’s view, the reasons advanced by the District Court to justify the adoption – namely the applicant’s poor cognitive functioning and poor caring skills, the child’s sensitivity and attachment to her foster parents compared to the limited bonds with her biological mother, and the adoptive parents’ openness to contact between the applicant and her daughter if and when her daughter had so wished – were relevant to the question of necessity. As to whether the reasons provided by the District Court had also been sufficient to justify the impugned measures, the Court reiterated that it had previously refrained from attempting to untangle the opposing considerations inherent in questions concerning whether adoption or long-term foster care might be in the best interests of a child in a specific case, and was not inclined to take a different approach in this case. However, the Court stressed that adoption as a rule entailed the severance of family ties to a degree that according to the Court’s case-law was only allowed in very exceptional circumstances. In the instant case, the Court noted, firstly, that it had no basis for calling into question the District Court’s findings that the applicant’s daughter had been vulnerable or that she had settled well into the foster home. The Court considered, however, that the District Court had provided […]
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Advocate General’s Opinion in Case C-896/19 Repubblika v Il-Prim Ministru, December 17, 2020

Advocate General Hogan : EU Law does not preclude national constitutional provisions under which the executive power or one of its members, such as the Prime Minister, plays a role in the process of the appointment of members of the judiciary. However, Article 19(1) TEU, read in the light of the right to a fair and effective trial under the Charter, is applicable when a national court is assessing the validity of a procedure for the appointment of judges such as that provided for by the Maltese Constitution. Repubblika is an association whose purpose is to promote the protection of justice and the rule of law in Malta. On 25 April 2019, it brought an actio popularis before the First Hall Civil Court, Constitutional jurisdiction (the referring court) challenging the system of appointments of judges and magistrates in force at the time the proceedings commenced, as regulated by Constitution of Malta. By its first question to the Court of Justice, the referring court seeks to establish whether the second subparagraph of Article 19(1) TEU (1) and Article 47 (2) of the Charter must be considered to be applicable when a national court is assessing the validity of a procedure for the appointment of judges such as that provided for by the Maltese Constitution. By its second question, the referring court asks, whether the aforementioned provisions must be interpreted as precluding national legislation under which the executive power, in this case the Prime Minister, enjoys a discretionary and decisive power in the process of the appointment of members of the judiciary. [49] Thirdly, the referring court asks, whether in the case where the power of the Prime Minister is found to be incompatible, this fact should be taken into consideration with regard to future appointments or whether it should also affect previous appointments. In today’s Opinion, Advocate General Gerard Hogan concludes that the second subparagraph of Article 19(1) TEU, read in the light of Article 47 of the Charter, is applicable when a national court is assessing the validity of a procedure for the appointment of judges such as that provided for by the Maltese Constitution. Secondly, he concludes that Article 19(1) TEU, interpreted in the light of Article 47 of the Charter, does not preclude national constitutional provisions under which the executive power or one of its members, such as the Prime Minister, plays a role in the process of the appointment of members of the judiciary. Finally, the Advocate General finds that the procedure for the appointment of judges at issue in the present case cannot be called into question under Article 19(1) TEU, interpreted in the light of Article 47 of the Charter, in support of claims introduced before the date of the forthcoming judgment. On the applicability of Article 19(1) TEU and Article 47 of the Charter Advocate General Hogan states that the Court has recently delivered a number of landmark judgments which undoubtedly allow this question to be answered in the affirmative. In the light of these judgments, it is now clear that although the organisation of justice in the Member States falls within the competence of the Member States, the fact remains that, when exercising that competence, the Member States are required to comply with their obligations deriving from EU law and, in particular, from the second subparagraph of Article 19(1) TEU (3). This obligation applies in particular in relation to any national body which can rule, as a court or tribunal, on questions concerning the application or interpretation of EU law and which therefore fall within the fields covered by that law (4). Additionally, the Advocate General notes that the Court itself has already ruled that ‘the second subparagraph of Article 19(1) TEU requires Member States to provide remedies that are sufficient to ensure effective legal protection, within the meaning in particular of Article 47 of the Charter, in the fields covered by EU law’ (5). On the discretionary power in the process of appointment of members of the judiciary In his general observations on the consequences of Article 19(1) TEU, Article 47 of the Charter and Article 6 ECHR on the procedures for the appointment of judges, Advocate General Hogan notes that the mere fact that judges are appointed by a member of the executive does not in itself give rise to a relationship of subordination of the former to the latter or raise doubts as to the former’s impartiality, if, once appointed, they are free from influence or pressure when carrying out their role. [55] He notes additionally that it would be pointless to deny that politics has played a role in the appointment of judges in many legal systems, including those in many Member States. The Advocate General concludes that it follows from the decisions in AK and Independence of the Supreme Court that neither EU law nor, for that matter, the ECHR impose any fixed, a priori form of institutional guarantees designed to ensure the independence of judges. What is important, however, is that, first, judges must be free from any relationship of subordination or hierarchical control by either the executive or the legislature and, second, judges must enjoy actual guarantees designed to shield them from such external pressures. In these circumstances, it is only if one of these aspects of the procedure for the appointment of judges were to present a defect of such a kind and of such gravity as to create a real risk that other branches of the State – in particular the executive – could exercise undue discretion via an appointment which was contrary to law, thereby undermining the integrity of the outcome of the appointment process (and thus giving rise in turn to a reasonable doubt in the minds of individuals as to the independence and the impartiality of the judge or judges concerned), that the appointment procedure in question might be contrary to Article 19(1) TEU. According to the Advocate General, the critical considerations, remain whether, viewed objectively, a national judge enjoys […]
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Advocate General’s Opinion in Case C-824/18 A.B. and others, December 17, 2020

Advocate General Tanchev: Polish law introduced in order to exclude the possibility for legal review of the National Council of the Judiciary’s assessment of judicial candidates to the Supreme Court violates EU law. The second subparagraph of Article 19(1) TEU can be applied directly by the referring court in order to disapply those national provisions and to declare itself competent to rule on the cases in the legal framework which was applicable before the adoption of that law. In the context of legal proceedings between candidates for judicial office A.B., C.D., E.F., G.H. and I.J., on the one hand, and the Krajowa Rada Sądownictwa (National Council of the Judiciary; ‘the KRS’), on the other, by which those candidates appealed against resolutions where: i) the KRS decided not to propose to the President of the Republic of Poland (‘the President of the Republic’) their appointment to the position of judge of the Sąd Najwyższy (Supreme Court, Poland); and at the same time, ii) the KRS proposed the appointment of other candidates to the President of the Republic, the Naczelny Sąd Administracyjny (Supreme Administrative Court, Poland) has referred the matter to the Court of Justice. The Polish law of 26 April 2019 (1) changed a provision of the law on the KRS, which is now worded as follows: ‘There shall be no right of appeal in individual cases regarding the appointment of Supreme Court Judges’. The same law also states that ‘proceedings in cases concerning appeals against [KRS] resolutions in individual cases regarding the appointment of Supreme Court Judges, which have been initiated but not concluded before this law comes into force, shall be discontinued by operation of law’. In today’s Opinion, Advocate General Evgeni Tanchev first examines whether EU law precludes a provision which causes national proceedings to be discontinued by operation of law without any possibility to continue those proceedings or to bring them again before a different court and whether EU law precludes the consequence which is liable to flow from that national provision in terms of the Court of Justice declining jurisdiction in cases which have already given rise to a reference for a preliminary ruling which is still pending. He recalls that the judicial system of the Union has as its keystone the preliminary ruling procedure, provided for in Article 267 TFEU, which, by setting up a dialogue between the Court of Justice and the courts and tribunals of the Member States, has the object of securing uniform interpretation of EU law, thereby serving to ensure its consistency, its full effect and its autonomy as well as, ultimately, the particular nature of the law established by the Treaties. It follows clearly from the Court’s case-law that, in accordance with that provision, national courts must remain free to decide whether to refer preliminary questions to the Court or not. The Advocate General considers therefore that EU law precludes a national law which decreed the discontinuation by operation of law of proceedings such as those before the referring court while at the same time excluding any transfer of the review of the appeals to another national court or the bringing again of the appeals before another national court. Moreover, such a national provision in a context where the national court originally having jurisdiction in those cases has referred questions to the Court of Justice for a preliminary ruling following the successful initiation of the procedure for reviewing the KRS resolutions, undermines the right of access to a court also in so far as, in the individual case pending before the court (originally) having jurisdiction to hear and determine it, it then denies that court both the possibility of successfully initiating preliminary ruling proceedings before the Court of Justice and the right to wait for a ruling from the Court, thereby undermining the EU principle of sincere cooperation. The Advocate General finds that the removal of the (right to a) judicial remedy which was until then available and, in particular, taking it away from litigants who have already brought such an action constitutes a measure whose nature contributes to – indeed reinforces – the absence of the appearance of independence and impartiality on the part of the judges actually appointed to the court concerned, and on the part of the court itself. Such an absence of the appearance of independence and impartiality violates the second subparagraph of Article 19(1) TEU. In the context of examining the primacy of EU law in the present case, Advocate General Tanchev addresses recent judgments from the Bundesverfassungsgericht (Federal Constitutional Court, Germany, ‘the BVerfG’) and from the Polish Supreme Court. The former ruled in Weiss (2) inter alia that a judgment of the Court of Justice was ultra vires and not applicable in Germany and the latter ruled (3) subsequently that a Court of Justice judgment was not binding in the Polish legal order. In particular, the Advocate General explains that, rather than endangering the whole system of the EU community based on the rule of law and taking such an unprecedented approach, the BVerfG could have explained what, in its view, was open to criticism in the case-law of the Court of Justice and could have sent a new reference for a preliminary ruling to the Court. The Advocate General underlines the importance of judicial dialogue, which is integral to the functioning of the EU legal order. According to the Advocate General, the BVerfG’s ultra vires approach undermines the rule of law in the EU, which is a conditio sine qua non to integration. Indeed, the rule of law serves as a bridge to deal with conflicts of courts. The Advocate General concludes essentially that according to the Treaties, which are the Member States’ ‘contract’, the final instance in EU law is the Court of Justice and so it is simply not the BVerfG’s role or competence to rule the way it did in Weiss. No national court is allowed by the Treaties to overrule a Court of Justice judgment, otherwise EU law […]
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ECJ judgment in Case C-693/18 CLCV and Others (Defeat device on diesel engines) , December 17, 2020

A manufacturer cannot install a defeat device which systematically improves, during approval procedures, the performance of the vehicle emission control system and thus obtain approval of the vehicle. The fact that it contributes to preventing the ageing or clogging up of the engine cannot justify the presence of such a defeat device. Company X is a car manufacturer that markets motor vehicles in France. That company placed on the market vehicles equipped with software capable of distorting the results of type-approval tests for emissions of gaseous pollutants, such as nitrogen oxides (‘NOx’). Following disclosures in the press, the Parquet de Paris (Prosecutor’s Office, Paris, France) conducted an investigation which resulted in the launch of a judicial investigation in respect of Company X. That company is alleged to have deceived the purchasers of diesel engine vehicles as to the essential qualities of those vehicles and the controls carried out before they were placed on the market. The vehicles at issue were fitted with an exhaust gas recirculation (EGR) valve. The EGR valve is one of the technologies used by car manufacturers in order to manage and reduce final NOx emissions. It is a system which consists in redirecting part of the exhaust gas from combustion engines to the gas inlet manifold, that is, the engine air supply, in order to reduce final NOx emissions. Before being placed on the market, those vehicles were subject to vehicle approval tests conducted in a laboratory using the New European Driving Cycle, the technical parameters of which are predefined (temperature, speed etc.). The purpose of those tests is, amongst other things, to ascertain the level of NOx emissions and the observance of the limits set by Regulation (EC) No 715/2007 (1) in that regard. The emissions of the vehicles at issue had therefore not been analysed under normal driving conditions. An expert’s report, produced in the context of the judicial investigation procedure, found that the vehicles in question were fitted with a device that allowed the phases of the approval procedure to be detected and the operation of the ERG system to be adjusted in order to observe the regulatory ceiling for emissions. Conversely, in conditions other than those of the approval tests, namely in normal conditions of vehicle use, that device leads to the (partial) deactivation of the EGR system and, as a result, to an increase in NOx emissions. The expert further stated that if the operation of the EGR system in actual traffic had been consistent with that during the approval tests, those vehicles would have produced significantly less NOx. Maintenance operations would, however, have been more frequent and expensive on account, amongst other things, of the engine clogging up more quickly. Regulation No 715/2007 expressly prohibits the use of defeat devices which reduce the effectiveness of emission control systems under normal conditions of vehicle use. The national court decided to refer the matter to the Court of Justice seeking clarifications, in particular with regard to the definition and the scope of the concepts of ‘emission control system’ and ‘defeat device’. In its judgment of today, the Court states that it must be examined, first, whether software installed on the engine control calculator or more generally acting on that calculator must be considered to be an ‘element of design’ for the purposes of Regulation No 715/2007. It recalls that the ‘defeat device’ is defined by that regulation as being ‘any element of design which senses temperature, vehicle speed, engine speed (RPM), transmission, gear, manifold vacuum or any other parameter for the purpose of activating, modulating, delaying or deactivating the operation of any part of the emission control system, that reduces the effectiveness of the emission control system under conditions which may reasonably be expected to be encountered in normal vehicle operation and use’. Next, the Court finds that the concept of ‘element of design’ is not defined in the legislation. It then states that the term ‘element of design’ designates, in its usual sense, an object manufactured with a view to its inclusion in a functional unit, and that it is clear from the regulation that the concept of ‘defeat device’ referred to therein designates ‘any’ element of design. The Court observes that the effectiveness of the depollution is linked to the opening of the EGR valve, which is controlled by the source code of the software installed on the calculator, and that, as a consequence, where it acts on the operation of the emission control system and reduces the effectiveness thereof, software, such as that at issue, installed on the engine control calculator, constitutes an ‘element of design’, for the purposes of Regulation No 715/2007. The Court goes on to determine whether the technology used in the EGR system which reduces emissions produced upstream – that is, when they are produced within the engine itself – comes within the scope of the concept of ‘emission control system’, for the purposes of the regulation. The Court finds that the regulation does not define the concept of ‘emission control system’ as such but recalls in its preamble that, having regard to the objective of reducing emissions set out therein, it is necessary to make provision for devices intended to measure and manage emissions while a vehicle is in use. The Court states, moreover, that the regulation sets the objective to be met by car manufacturers, namely to limit tailpipe emissions, without specifying the means to achieve it. The text provides that any technical measures taken by the manufacturer must be such as to guarantee the effective limitation, amongst other things, of tailpipe emissions, throughout the normal life of vehicles, under normal conditions of use. The Court recalls that, in vehicle typeapproval procedures, emissions levels are always measured at the outlet of the exhaust pipe. Thus no distinction can be made between the strategy for reducing exhaust gas emissions after these are produced and that intended to limit the production of those emissions. It is therefore apparent from Regulation No 715/2007 that the […]
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ECJ judgment in Case C-490/19 Syndicat interprofessionnel de défense du fromage Morbier v Société Fromagère du Livradois SAS, December 17, 2020

EU law prohibits the reproduction of the shape or appearance of a product protected by a PDO in certain circumstances. It is necessary to determine whether that reproduction may mislead consumers taking into account all the relevant factors, including the way in which the product is presented to the public and marketed and the factual context. Morbier is a cheese produced in the Jura mountains (France) which has enjoyed a protected designation of origin (PDO) since 22 December 2000. It is characterised by the presence of a black line which divides the cheese in two horizontally. That black line, originally made from a layer of cinder and now made from vegetable carbon, is expressly referred to in the product description in the specification for the PDO. Société Fromagère du Livradois SAS, which has produced Morbier cheese since 1979, is not situated within the geographical area reserved for the name ‘Morbier’. From the expiry of a transitional period it has therefore used the name ‘Montboissié du Haut Livradois’ for its cheese. In 2013, the Syndicat interprofessionnel de défense du fromage Morbier (‘the Syndicat’) brought proceedings against Société fromagère du Livradois before the Tribunal de grande instance de Paris (Regional Court, Paris, France). The Syndicat accuses Société Fromagère du Livradois of infringing the PDO and committing acts of unfair and parasitic competition by producing and marketing a cheese that reproduces the visual appearance of ‘Morbier’, the product covered by the PDO, in particular the black line. Its action was dismissed. By a 2017 judgment, the cour d’appel de Paris (Court of Appeal, Paris, France) upheld that decision. That court held that the PDO is intended to protect not the appearance or features of a product but its name, so that the production of a product using the same techniques is not prohibited. The Syndicat therefore appealed on a point of law to the referring court. In those circumstances, the Cour de cassation (Court of Cassation, France) seeks a ruling by the Court of Justice on the interpretation of Article 13(1) of Regulation No 510/2006 (1) and Article 13(1) of Regulation No 1151/2012 (2), which concern the protection of registered names. In particular, the question arises as to whether the reproduction of the physical characteristics of a product covered by a PDO without the use of the registered name may constitute a practice that is liable to mislead the consumer as to the true origin of the product, which is prohibited by Article 13(1)(d) of those two regulations. The Court therefore finds it necessary, for the first time, to interpret Article 13(1)(d) of both of those regulations. Findings of the Court The Court finds, in the first place, that Article 13(1) of Regulation No 510/2006 and Article 13(1) of Regulation No 1151/2012 do not prohibit solely the use by a third party of the registered name. In the second place, the Court states that Article 13(1)(d) of both of those regulations prohibits the reproduction of the shape or appearance characterising a product covered by a registered name where that reproduction may lead the consumer to believe the product in question is covered by that registered name. In that regard, it is necessary to assess whether that reproduction may mislead the European consumer, who is reasonably well informed and reasonably observant and circumspect, taking into account all the relevant factors in the case, including the way in which the products in question are presented to the public and marketed and the factual context. In reaching those findings, the Court notes, first of all, that Article 13(1) of Regulation No 510/2006 and Article 13(1) of Regulation No 1151/2012 contain a graduated list of prohibited conduct and do not merely prohibit the use of the registered name itself. Thus, although they do not specify the prohibited conduct, Articles 13(1)(d) of both of those regulations broadly cover any conduct, other than that prohibited by Articles 13(1)(a) to (c), which may result in the consumer being misled as to the true origin of the product in question. Concerning, next, whether the reproduction of the shape or appearance of a product covered by a registered name may constitute conduct liable to mislead the consumer, the Court observes that, indeed, the protection provided for by Regulations No 510/2006 and No 1151/2012 concerns the registered name and not the product covered by that name. It follows that the purpose of that protection is not to prohibit the use of manufacturing techniques or the reproduction of one or more characteristics indicated in the specification of a product covered by a registered name, on the ground that they appear in that specification. Nevertheless, PDOs are protected as they designate a product that has certain qualities or characteristics. Thus, the PDO and the product covered by it are closely linked. Therefore, the possibility remains that the reproduction of the shape or appearance of a product covered by a registered name may fall within the scope of Article 13(1)(d) of both of those regulations without that name appearing either on the product in question or on its packaging. This will be the case where that reproduction is liable to mislead the consumer as to the true origin of the product in question. In order to determine whether that is the case, it is necessary, in particular, to assess whether an element of the appearance of the product covered by the registered name constitutes a baseline characteristic which is particularly distinctive of that product so that its reproduction may, in conjunction with all the relevant factors in the case in point, lead the consumer to believe that the product containing that reproduction is a product covered by that registered name. Footnotes: (1) Council Regulation (EC) No 510/2006 of 20 March 2006 on the protection of geographical indications and designations of origin for agricultural products and foodstuffs (OJ 2006 L 93, p.12). (2) Regulation (EU) No 1151/2012 of the European Parliament and of the Council of 21 November 2012 on quality schemes for agricultural products and […]
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ECJ judgment in Case C-398/19 Generalstaatsanwaltschaft Berlin, December 17, 2020

A Union citizen may be extradited to a third State only after consultation with the Member State of which that citizen is a national. As part of that consultation, the Member State of nationality must be informed by the Member State from which extradition is requested of all the elements of fact and law communicated in the extradition request and must be allowed a reasonable time to issue any European arrest warrant in respect of that citizen. BY, who is a national of both Ukraine and Romania, was born in Ukraine and lived in that State until he moved to Germany in 2012. In 2014 he applied for and obtained Romanian nationality as a descendant of Romanian nationals, but he has never resided in Romania. In March 2016 the German authorities received from the General Prosecutor’s Office of Ukraine a request for the extradition of BY, for the purpose of conducting a criminal prosecution. In November 2016 the Generalstaatsanwaltschaft Berlin (General Prosecutor’s Office in Berlin, Germany) informed the Romanian Ministry of Justice of the extradition request and asked whether the Romanian authorities envisaged that they would themselves conduct a criminal prosecution of BY. The Romanian Ministry of Justice replied, first, that the Romanian authorities could make a decision to conduct a criminal prosecution only if requested to do so by the Ukrainian judicial authorities and, second, that the issue of a national arrest warrant, as a prerequisite for the issue of a European arrest warrant, was subject to there being sufficient evidence of the guilt of person concerned. That ministry therefore asked the German authorities to provide it with the evidence that had been sent to them by the Ukrainian authorities. German law prohibits the extradition of German nationals, but not the extradition of nationals of other Member States. Accordingly, the Kammergericht Berlin (Higher Regional Court of Berlin, Germany) considers that the extradition of BY to Ukraine is lawful, but it is uncertain whether that extradition is not incompatible with the principles set out by the Court in the Petruhhin judgment (1), given that the Romanian judicial authorities have not formally made a decision on the possible issue of a European arrest warrant. In the abovementioned judgment, the Court held, in particular, that, when a Member State to which a national of another Member State has moved has received an extradition request from a third State, it is obliged to inform the Member State of which the person whose extradition is requested is a national in order to give the authorities of the latter Member State the opportunity to issue a European arrest warrant for the surrender of that person for criminal prosecution. That court was uncertain as to the consequences of that judgment for the outcome of the case before it, and submitted to the Court three questions for a preliminary ruling, concerning the interpretation of Articles 18 and 21 TFEU (relating to, respectively, the principle of non-discrimination on grounds of nationality and the right of Union citizens to move and reside freely within the territory of the Member States) and of the Petruhhin judgment. Findings of the Court The Grand Chamber of the Court examines, first, whether Articles 18 and 21 TFEU are applicable to the situation of a Union citizen such as the person concerned in the main proceedings. In that regard, the Court states that, in accordance with its case-law, a national of one Member State, who thereby has Union citizenship and who is residing in the territory of another Member State, is entitled to rely on Article 21(1) TFEU and falls within the scope of the Treaties, within the meaning of Article 18 TFEU. The fact that BY acquired the nationality of a Member State only at a time when he was already residing in a Member State other than that of which he subsequently became a national has no effect in that respect. Second, the Court clarifies the obligations incumbent on the Member States in the exchanging of information referred to in the Petruhhin judgment. In that regard, the Court states that the Member State from which extradition is requested (‘the requested Member State’) must put the competent authorities of the Member State of which the person whose extradition is requested is a national in a position to request the surrender of that person by means of a European arrest warrant. In order to do so, the requested Member State must inform those authorities not only of the existence of an extradition request, but also of all the elements of fact and law communicated by the third State requesting extradition in the context of that extradition request. It must also give notice of any change in the situation of the person whose extradition is requested that might be relevant to the possibility of the issue of a European arrest warrant in respect of that person. However, neither of those Member States is obliged, under EU law, to ask the third State that is requesting extradition to send the criminal investigation file, in order to permit the Member State of which the person concerned is a national to assess the possibility that it might itself conduct a criminal prosecution of that person. The Court states that, provided that that obligation to inform has been respected, the authorities of the requested Member State may continue the extradition procedure and, if appropriate, carry out the extradition of the person concerned where no European arrest warrant has been issued, within a reasonable time, by the authorities of the Member State of which that person is a national. A reasonable time limit must be imposed, by the requested Member State, on those authorities, that time limit being set taking account of all the circumstances of the case, in particular whether the person concerned is in custody on the basis of the extradition procedure and the complexity of the case. Third, the Court holds that Articles 18 and 21 TFEU cannot be interpreted as meaning that the requested Member […]
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ECJ judgment in Case C-449/19 WEG Tevesstraße v Finanzamt Villingen-Schwenningen, December 17, 2020

The supply of heat by a group of residential property owners to its members is subject to VAT. This economic activity does come under the exemption under the VAT Directive for leasing or letting immovable property. The WEG Tevesstraße, an association of residential property owners and co-owners comprising a limited liability company, a public authority and a municipality, operates a cogeneration power unit on land belonging to its members. The electricity produced is supplied by WEG Tevestraße to an energy distribution company, but the heat produced is supplied to its members. As regards the supply of heat, the Finanzamt Villingen-Schwenningen (Villingen-Schwenningen tax office, Germany) refused (1) the deduction of input value added tax (VAT) in connection with the purchase and operation of the cogeneration power unit on the ground that the supply of heat by an association of property owners to its members is a transaction that is exempt from VAT under the German law on turnover taxes. The Finanzgericht Baden-Württemberg (Finance Court, Baden-Württemberg, Germany), hearing the action brought by the WEG Tevesstraße, asked the Court of Justice whether the VAT Directive (2) precludes national legislation which exempts from VAT the supply of heat by an association of residential property owners to its members. By today’s judgment, the Court replies in the affirmative. The Court indicates, first, that the VAT Directive applies in the present case and that the supply of heat in question is a supply of property that is, in principle, subject to VAT. In that regard, the Court states, inter alia, that the supply of heat by the WEG Tevesstraße is an economic activity. First, its members appear to pay it consideration based on their individual consumption and, secondly, it is irrelevant whether or not that activity is intended to generate profits and, even if this matter concerns functions assigned by national legislation, that fact is in itself irrelevant for the purposes of the classification of an economic activity. The Court finds, next, that the provision of the VAT Directive, according to which Member States exempt ‘the leasing or letting of immovable property’ from VAT, does not make it possible to exempt from VAT the supply of heat by an association of property owner to its members, as the German law on turnover taxes does. The exemption laid down by the VAT Directive is explained by the fact that the letting of immovable property, whilst it is an economic activity, is normally a relatively passive activity, not generating any significant added value. However, by supplying the heat, the WEG Tevesstraße simply sells tangible property which is the result of the exploitation of another tangible property, albeit the latter is immovable, without however conferring on the purchasers of the heat, that is to say its members, the right to occupy an immovable property, in the present case the cogeneration power unit, and to exclude any other person from enjoyment of such a right. The Court adds that the exemption from VAT of the supply of heat by an association of residential property owners to its members, as provided for by the German law on turnover taxes, cannot be justified by a declaration of the Council and the Commission in a report from a meeting of the Council in 1977 (3), according to which Member States may provide for such an exemption. Neither the current VAT Directive nor the directive which preceded it contain the slightest evidence that that declaration was reflected in those provisions. Footnotes: (1) However, for the part relating to the production electricity, the Finanzamt Villingen-Schwenningen allowed the input VAT deduction. (2) Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ 2006 L 347, p. 1), as amended by Council Directive 2009/162/EU of 22 December 2009 (OJ 2010 L 10, p. 14). (‘the VAT Directive’). (3) Report No 7 of the meeting of the Council of the European Union of 17 May 1977 concerning Article 13 of the Sixth Directive. NOTE: A reference for a preliminary ruling allows the courts and tribunals of the Member States, in disputes which have been brought before them, to refer questions to the Court of Justice about the interpretation of EU law or the validity of a European Union act. The Court of Justice does not decide the dispute itself. It is for the national court or tribunal to dispose of the case in accordance with the Court’s decision, which is similarly binding on other national courts or tribunals before which a similar issue is raised. Unofficial document for media use, not binding on the Court of Justice. The full text of the judgment is published on the CURIA website on the day of delivery. Source: www.curia.eu
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ECJ judgment in Case C-667/19 A.M. v E.M., December 17, 2020

Information as to the ‘function’ of a cosmetic product which must appear on the product’s container and its packaging must inform consumers clearly as to that product’s purpose and method of use. Information concerning the particular precautions to be observed when using that product, its function and its ingredients may not appear in a company catalogue referred to by the symbol of a hand with an open book placed on the packaging or the container. In 2016 A.M., who, inter alia, owns a beauty salon in Poland, purchased creams, facial masks and powders from a manufacturer based in the United States via E.M., distributor of those products. The packaging of those products bore the name of the responsible entity, the original name of the cosmetic product, its composition, expiry date and serial number as well as the following symbol, representing a hand with an open book, referring to a catalogue containing all the information in Polish. A.M. terminated the contract for the sale of those products, claiming that there was no Polish language information on the packaging regarding the product’s function, which made it impossible to identify what the product was and what its effects were, and that that information was not clear from the presentation. She also claimed that the information in Polish, required under Polish law and arising from EU law, appeared only in the catalogue, which is not enclosed with or attached to the product. Since her action seeking reimbursement of the costs of purchasing those products was dismissed, A.M. brought an appeal before the Sąd Okręgowy w Warszawie XXIII Wydział Gospodarczy Odwoławczy (Regional Court, Warsaw, Commercial Appeals Division No 23, Poland). That court asked the Court of Justice to interpret the EU regulation on cosmetic products (1). By today’s judgment, the Court recalls, first of all, that that regulation seeks to harmonise comprehensively the rules in the European Union in order to achieve an internal market for cosmetic products while ensuring a high level of protection of human health. It points out in that regard that there is a close connection between, on the one hand, the safety of cosmetic products placed on the market and, on the other hand, the requirements concerning how they are presented and labelled. It follows that the requirement to provide information in indelible, easily legible and visible lettering on the container and on the packaging of cosmetic products concerning the function of the cosmetic product (2) cannot be confined to a requirement to provide information on the purposes of the product’s use, namely to clean, to perfume, to change the appearance, to protect or to keep a part of the body in good condition or to correct body odours. Whilst those purposes make it possible to assess whether a particular product, depending on its use and its purpose, may be categorised as a cosmetic product and therefore, may be distinguished from other products falling outside the scope of the regulation, the ‘function of the cosmetic product’ concerns information relating to characteristics more specific to the product. The Court concludes that the information as to the ‘function of a cosmetic product’ which must appear on such a product’s container and packaging must be such as to inform consumers clearly as to the product’s purpose and method of use, in order to ensure that consumers can use that product safely, without negatively affecting their health. It is for the national courts, in the light of the characteristics and properties of the product concerned as well as the expectations of the average consumer, who is reasonably well informed and reasonably observant and circumspect, to review the nature and extent of the information which must appear in that regard on the product’s packaging and container so that it can be used without risk to human health. Next, the Court considers whether the information concerning particular precautions for use of a cosmetic product, its function and its ingredients may appear in a company catalogue which also includes other products, where the symbol of a hand with an open book is placed on the cosmetic product’s packaging or container. It finds that, when a reference must be provided, only an ‘enclosed or attached leaflet, label, tape, tag or card’ may be used as supporting documentation for the cosmetic product. A company catalogue which is provided separately and contains a description of one or more cosmetic products at issue, but also describes other products from the manufacturer’s range, is not enclosed or attached to a specific product. In addition, supporting documentation may be used only where it is impossible ‘for practical reasons’ to place that information on the label. Such impossibility refers to situations where it is impossible in practice, on account of the nature and the actual presentation of the product, to place certain information on the label. In that regard, the fact that the cosmetic products concerned have been imported – which, in view of the requirement to place on the label the required information in the language determined by the law of the Member States in which the product is made available to end users, may give rise to organisational and financial issues stemming from the need to translate certain information and to relabel or even repackage the products – does not in itself establish that it is impossible in practice to place that information on the label. The cost of labelling those products in a different language in order to market them in other Member States cannot in any case be regarded as justifying incomplete labelling of the product on its container and its packaging. The Court finds that such a requirement ensures a high level of protection for consumers. Protection of health cannot in fact be fully guaranteed if consumers are not in a position to familiarise themselves fully with, and to understand, in particular, the information concerning the function of the cosmetic product concerned and the particular precautions to be observed when using it. The Court finds that the information […]
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