Introduction

10.1 The United Kingdom's withdrawal from the European Union (EU), and the European Commission's decision to oppose the UK's application to accede to the Lugano Convention, has removed from the jurisdictional rules applied by the English court1 the sharp, immediate distinction drawn between cases where the defendant is domiciled in an EU member state and where it is not. All cases are now to be dealt with in accordance with the English, as opposed to EU, principles of private international law,2 albeit that those rules have undergone some limited modification post-Brexit.