The 2005 Hague Choice of Court and the 2019 Hague Judgments Conventions versus the New York Convention: Rivals, Alternatives or Something Else?
Bibliographic record
Abstract
The 2019 Hague Judgments Convention is the culmination of almost 50 years of work in this area by the Hague Conference on Private International Law (HCCH) and together with the 2005 Choice of Court Convention (hereafter the 'Hague Conventions') creates a system which operates as the litigation equivalent to the New York Convention enabling harmonised recognition and enforcement of judgments throughout the globe. The aim of this essay is to compare the Hague Conventions with the New York Convention and establish whether the former are a rival, alternative or something else altogether for the latter. In order to do so this essay will look at four main issues (i) the obligations imposed on states under the Hague Conventions and the New York Convention, (ii) the scope of the Hague Conventions and the New York Convention, (iii) grounds for refusal of recognition or enforcement under the Hague Conventions and the New York Convention, and (iv) Reservations available under the Hague and New York Conventions.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.011 | 0.033 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.000 |
| Bibliometrics | 0.002 | 0.003 |
| Science and technology studies | 0.011 | 0.017 |
| Scholarly communication | 0.027 | 0.011 |
| Open science | 0.002 | 0.004 |
| Research integrity | 0.011 | 0.011 |
| Insufficient payload (model declined to judge) | 0.008 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".