In Sabeh el Leil v. France, the European Court of Human Rights (‘‘ECtHR’’ or ‘‘the Court’’) ruled for the second time that a contracting state had violated the right to a fair trial afforded by Article 6 of the European Convention for the Protection of Human Rights and Fundamental Freedoms (‘‘Convention’’) by denying access to its courts to an embassy employee suing for wrongful dismissal on the grounds that the employer enjoyed sovereign immunity. The ECtHR had first ruled so a year earlier in Cudak v. Lithuania, where the plaintiff was also an embassy employee.

On August 30, 2011, a majority of the Appeals Chamber of the International Criminal Court (‘‘ICC’’) rejected the appeal of the Government of Kenya to the earlier admissibility decision of Pre-Trial Chamber II in the case of Prosecutor v. Francis Kirimi Muthaura, Uhuru Muigai Kenyatta and Mohammed Hussein Ali, one of two cases arising from the ICC’s investigations into crimes against humanity committed during the 2007 post-election violence in Kenya.

On July 7, 2011, the United States Supreme Court declined to stay the execution of Humberto Leal García, a Mexican national who had been convicted some sixteen years ago in Texas of murder.1 Relying on the decision of the International Court of Justice (‘‘ICJ’’) in the Avena case,2 García contended that the United States had violated his right to consular notification and access under the Vienna Convention on Consular Relations (‘‘Consular Convention’’).3 He sought the stay so that the U.S. Congress could consider enactment of proposed legislation to implement the ICJ decision.4 In a 5-4 decision, the Court rejected his argument, stating that ‘‘[t]he Due Process Clause does not prohibit a State from carrying out a lawful judgment in light of unenacted legislation that might someday authorize a collateral attack on that judgment.’’5 García was executed by lethal injection that evening.

On July 21, 2011, the Inter-American Commission on Human Rights (‘‘IACHR’’ or the ‘‘Commission’’) issued a landmark decision finding that the United States had breached its international legal obligations to exercise due diligence to protect women from domestic violence. The decision holds profound ramifications for states’ responsibility to protect individuals from harm imposed by private actors and to protect women and girl-children from domestic violence.

The Council of Europe Convention on Preventing and Combating Violence against Women and Domestic Violence (‘‘Convention’’) joins a small number of treaties imposing specific obligations on member states to prevent and address violence against women. The Convention is notable both for its encapsulation of best practices in combating violence against women and for its confirmation that all forms of violence against women, including domestic violence, are human rights violations for which states are responsible.

Because of the unique position that Hong Kong occupies in China and its separate legal system based on the common law, it is a well-established policy of the Hong Kong Special Administrative Region (‘‘HKSAR’’) Government to develop and enhance Hong Kong’s status as a major dispute resolution centre in the Asia Pacific region. One significant initiative in this regard is the recent introduction of a new Arbitration Ordinance to further improve the legal environment for arbitration in Hong Kong.

On February 22, 2011, the Energy Ministers and representatives of eighty-six countries, including energy producers, consumers, and transit countries, met in Riyadh, Saudi Arabia for an Extraordinary Ministerial Meeting of the International Energy Forum (‘‘IEF’’) where they approved and signed a new charter for the IEF (‘‘IEF Charter’’). The IEF Charter creates an ‘‘enhanced IEF framework to sustain and reinforce the commitment of producer and consumer states to the informal dialogue’’ promoted through the IEF process.