This book deals with the two new important Conventions relating to jurisdiction and the enforcement of judgments. The Lugano extends the principles of the Brussels Convention to the EFTA countries; the San Sebastian Convention provides for the accession of Spain to the Brussels Convention, while making some amendments to the Brussels Convention. The book is in two parts. There are 73 pages of textual commentary on the Conventions and 136 pages of appendices.

The text consists of four essays, two each by English and Swiss lawyers, based on papers presented at a Conference in Interlaken in August 1989. As a result the papers do not purport to be a systematic commentary on the Conventions. The essays by the English lawyers are useful introductions to the two Conventions. The Lugano Convention provides substantially the same rules of jurisdiction for Contracting States outside the EC as the Brussels Convention does for EC States. In so doing it enables the extension of the principle of free movement of judgments throughout all EFTA and EC States. Michael Carpenter provides a lucid sketch of the background to the Lugano Convention and how it fits in with the Brussels Convention.

The San Sebastian Convention not only allowed for the accession of Spain and Portugal to the Judgments Convention, but it also provides for modifications to the Convention, based largely on the problems highlighted by cases before the European Court of Justice. Thus, in Ivenel v. Schwab [1982] ECR 1891 the European Court of Justice adopted a strained and linguistically indefensible interpretation of Art. 5(1), in order to allow an employee to sue in the courts of the country in which he worked. In Rösler v. Rottwinkel [1986] ECR 99 the exclusive jurisdiction of the courts of the situs of land was shown to be inappropriate for some holiday lets. Tony Hunter-Tilney explains the history and describes the effect of these and other changes.

While the English contributions are general and expository, the Swiss contributions are rather different, concentrating as they do on specific aspects of the Lugano Convention from the point of view of a Swiss lawyer. That by Professor Volken explains why Switzerland negotiated a right of reservation to Art. 5(1) of the Convention, conferring jurisdiction on the courts of the place in which the contractual obligation in question was to be performed. It is because the right to be sued only in the place of domicile, rather than the place of performance, is protected by the Constitution. The remainder of the paper is a series of critical observations of certain aspects of the Convention.

The contribution by Michael Haymann, entitled “Contract Drafting Problems in the Light of the Lugano Convention”, is the most original paper and will be of particular interest to practitioners. Ultimately his advice is not new. Choose your forum expressly and be precise. Choose the applicable law at the same time and be aware of the procedural, public policy and conflict of laws rules of the chosen forum and law. Indeed, his discussion of the extent to which the Convention will extend the effective scope of EC law demonstrates what a big step ratification of the Convention will be for EFTA countries. It is no wonder then that, as the EFTA countries bcome forced into closer relationship with the EC, they are contemplating joining the bloc and having a say in its decision-making.

However, the bulk of this book is taken up with the appendices, containing the Lugano