12.01 Choice-of-court agreements in insurance contracts fall within the scope of all the instruments; however, there is an important difference between the European instruments – Brussels and Lugano – on the one hand, and Hague on the other. Under the Hague Convention, insurance contracts are treated like any others; under the European instruments, the policy with regard to insurance is the same as that with regard to consumer contracts and individual employment contracts. In Brussels 2000 and 2012, this is expressed as follows in a Recital:1 In relation to...
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