Research

Projects

A total of 21 Research Projects have been approved by the Board of Directors to be developed within the scope of CIDP’s different thematic lines in the period 2024-2029.

Research Lines

Artificial Intelligence and Labour Law

The Research Centre for Private Law (CIDP) of the Faculty of Law of the University of Lisbon has always included in the scope of its research the field of Labour Law, an area that has been pursued essentially through the Institute of Labour Law (IDT).
The aim is now to take advantage of the knowledge and research experience accumulated in recent years within the IDT framework to carry out a variety of joint initiatives exploring the area of ​​Artificial Intelligence and its repercussions on Labour Law.
The project thus foresees to hold intensive and postgraduate courses, as well as conferences and publications. The aim of these activities is to study the various impacts that technology has had on the world of work, with an emphasis on the use of algorithms, work on digital platforms and worker selection criteria, among other aspects. The investigation will take into account both the national and the European legal frameworks, whilst also considering experience in other legal systems.
The project will consist of 2 main phases.
Phase 1 begins in 2025 and comprises the following 3 subphases:

  1. International conference – Work in the digital world;
  2. I Intensive Course – Artificial Intelligence and Work;
  3. I Postgraduate Course in Technology and Labour Law.

 

Phase 2 includes:

  1. II, III and IV Intensive Course – Artificial Intelligence and Work;
  2. II, III and IV Postgraduate Course in Technology and Labour Law;
  3. Publication of the proceedings of the International Conference – Work in the digital world;
  4. Publication of the Annotation to the norms with labour implications of the European Artificial Intelligence Regulation.

 

All planned activities will include national and international researchers, particularly from entities that have already established collaborative relationships with IDT and with which specific partnerships will be developed within the scope of this project.

The intended objectives of this project, which seeks to encourage the study of the effects of Technology in Labour Law and contribute to its development in Portuguese and European Law, are:

  • the publication of the works mentioned above in a national or international publisher of reference;
  • to fill a gap in the national context in the integrated treatment of the project theme;
  • to provide jurists, companies and other public and private collective entities with specific knowledge in this area.
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Artificial Intelligence and Procedural Guarantees

Technological development, global access to the internet, the physical dematerialisation of evidence and the growing importance of the influence of artificial intelligence are key trends today. It is therefore unavoidable to critically study the interaction between artificial intelligence and civil procedure, be it in the processing of the case, in the control and verification of procedural requirements, in the preparation of orders, in the production and evaluation of evidence, and finally in the preparation and drafting of the decision.

 

The advantages appear to be manifold, multi-faceted and very relevant: think of the increases in speed and efficiency in litigation, the medium-term reduction in the cost of justice and the mitigation of the risk of human error. However, it is important not to overlook the obstacles that arise when the effects of applying AI to the process are placed in the light of values dear to Civil Procedural Law.

 

One example that immediately springs to mind is the potential shortcomings in the explainability of decisions produced by autonomous systems, which could imply a lack of justification for the judicial decision, in conflict, therefore, with a right of the parties that, in our country, deserves constitutional protection. Predictive justice is also a source of relevant axiological doubts. It is announced as a very useful tool, especially from the perspective of lawyers, as it could make it possible to predict the outcome of a claim depending on the court that will judge it.

 

However, at this point the risk arises that judges will be conditioned by previous decisions, no longer because of an institutional precedent, but because of a coherence argument, which may well be introduced in closing arguments by lawyers. Once available on the market, such a tool could also be used by judges, with self-conditioning effects equivalent to those mentioned above. Moreover, such predictive tools or similar technologies could even make it possible to build machines capable of autonomously producing a decision. Once the facts have been established, either by agreement or by a human judge, the machine will simply search the database for factually and legally similar cases, adopting the statistically prevailing decision.

 

This possibility raises interesting questions: starting with the risk of data bias, and ending with the ablation of one of the driving forces behind the evolution of the law, which is the controversy over the best solution to the case. To conclude the list of examples, it should not be forgotten that the development of technology is (and may continue to be) an expensive business, which forces software companies to sell their products at high prices or to many people at a more affordable price.

 

In Portugal, any market is known to be small in size, and this is confirmed by the trade in products aimed at legal professionals. Therefore, if we accept the need to set a high price for these products, we will probably create information and resources asymmetries, since litigants with greater economic capacity will be able to benefit from AI tools that give them significant advantages, while others will not, which will accentuate pre-existing imbalances.

 

Diagnosing the risks is fundamental, but insufficient, especially if we accept that the advance of technology and its use is inevitable, as well as the real advantages that can be extracted from it for civil proceedings. Therefore, the next step is to understand and propose ways of preventing or eliminating the risks identified. This completes the course of a reflective but also practically relevant study.

 

This project is concerned only with civil proceedings. It would naturally be possible to cover other processes in which these issues are relevant, such as criminal proceedings, but the risk of dispersion is high enough to recommend a more restricted scope. What has been said does not rule out the clear susceptibility of generalising the conclusions reached with reference to civil proceedings to other cases.

 

The legal framework for this project is Portuguese. However, the integration of foreign researchers seems very pertinent, as it will make it possible to learn about, compare and integrate current thinking in other legal systems on identical issues. As this project deals with legal issues permeated by technology, it is essential to have consultants from the fields of computing in general and artificial intelligence in particular.

 

Decoding the nature and mode of operation of the machines, as well as clarifying doubts about the type of technology under analysis, is essential if the research is to be both rigorous and adherent to reality. The partnership with the Max Planck Institute Luxembourg for International, European and Regulatory Procedural Law is expected to be extremely fruitful, given that it is a research centre of excellence in the area of civil procedure. The partnership involves the participation of a researcher from the MPI Luxembourg in the project, as well as the organisation of research periods for the project's researchers at the MPI Luxembourg.

 

As there are several sub-questions to be answered, four teams of researchers will be formed, each dealing specifically with one (or possibly two) sub-questions. This split does not imply a breakdown of the research, but rather a continuous collaboration between all the researchers, which will materialise in joint meetings.

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Data Protection Litigation

The entry into force of the GDPR in 2018 revolutionised data protection law. The changes introduced were felt particularly strongly in legal systems where, until then, Data Protection Law had played a very discreet role, such as the Portuguese legal system.

 

In the last 6 years, Data Protection Law has achieved a remarkable degree of implementation, especially at the level of companies and university scientific research. However, there is a considerable gap in what we can call Data Protection Litigation, which covers all litigation in the courts, both civil and administrative, but also complaints lodged with supervisory authorities.

 

Recognising this gap, the aim is to launch a project which, (i) on the one hand, makes it possible to map Portuguese Data Protection Litigation, i.e. to carry out a survey of all related matters, namely complaints lodged with the CNPD; internal difficulties experienced by Data Protection Officers; procedural solutions tested by lawyers, and case law decisions. The data collected will be analysed and compiled into a White Paper on Data Protection Litigation; and (ii) on the other hand, to bring together specialists in this sub-area of Data Protection Law at three international conferences, with a view to producing the first collective work on Data Protection Litigation.

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Digital Sovereignty

Digital sovereignty has taken centre stage in recent debates on digital technologies as a result of the development of these technologies and the realisation that the resources needed for this development are scarce and their control allows states to assume a position of hegemony over others. Control of data, semiconductor technologies and programming, among others, is increasingly decisive for a state's sovereignty.

 

The project aims to (i) investigate the strategies that states and associations of states are outlining with a view to guaranteeing their digital sovereignty, including data sovereignty and technological sovereignty; (ii) identify the legal framework that is being outlined in this regard; and (iii) point out possible political and legislative ways forward in this area.

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Contractual Autonomy Under Scrutiny – Analysing the Boundaries of Shareholders' Freedom in Shareholders' Agreements

Even though private autonomy is a recognised historical and axiological foundation of Portuguese law (in particular, Portuguese Civil law), both its content and limits are not easily determined. Particularly in the corporate universe, marked by the sharp and rapid transformation of organisations, the discussion around contractual freedom is constantly changing as it is successively tested due to the creation or importation of legal institutes and the different needs of the agents in those organisations.

 

The widespread existence of doubts regarding the limits of such contractual freedom has fuelled disputes among scholars about the matters to be regulated in both the articles of association and the shareholders' agreements. The debate has effectively shaped the progress in this field: it has made it possible to overcome doubts about the admissibility of the shareholders’ agreement or even to provide stability to the debate of who could be a party to those agreements. The discussion, however, does not end in the contractual design of shareholders' agreements. It is necessary to position the discussion on the compatibility of the various clauses imported from international practice with Portuguese law (which creates serious obstacles to the contracting with both national and international investors) and the ethical challenges raised either by the parallel organisation that results from shareholders’ agreements or its definition of business plans and objectives "in the shadows".

 

These reflections, while necessary, need to be brought closer to the market and the practitioners as a way to provide stability to these issues in a concrete contractual body that will allow us to guide the discussion on the limits of parasociality with agents. This is our main goal with this project: to influence the practice of shareholders’ agreements in terms of efficiency and business ethics, taking advantage of the legal system potential.

 

To this end, we seek an innovative analysis based not only on the close dialogue with practitioners, but also on the most needed synergy with other scientific areas that influence legal solutions, such as business and, in particular, business management. As such, as we are driven by the need to broaden the discussion not only to economic agents, but also to academics in these areas, we have established formal/informal collaborations.

 

This research project falls within the scope of the CIDP's research line on New Perspectives on Corporate Governance and represents one of the main transformations in Corporate Law. The scope of the research is further connected to the other research lines approved for the 2024/2029 period and, in general, with the objectives pursued by the CIDP. The discussion on the content and limits of contractual freedom, even though it is focused on shareholders' agreements, is of transversal importance to legal science and, in particular, to private law. It is therefore a central area for common and commercial private law and constitutes one of its historical, dogmatic and axiological foundations, in line with the study of the Foundations of Private Law. The methodology adopted and the results of the research also aim to reflect the diversity of private law, in line with the approach to comparative law underlying the research line Diversity, Harmonisation and Unification of Private Law.

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DEBT LAB: Navigating Credit Default, Distressed Debt, Debt Restructuring, and Non-Performing Loans

The Portuguese economy has traditionally leaned heavily on bank lending as its primary source of capital for both individuals and companies. Whether for personal consumption or business expansion, obtaining credit from banks has been the go-to option when access to financial resources is needed.

 

Such reliance on bank lending has shaped our economic landscape. For individuals, bank lending plays a pivotal role in facilitating access to home mortgages, personal loans and credit cards. The availability of such lending has allowed borrowers to purchase homes, finance education, or address unexpected expenses. Moreover, it has shaped consumer behaviour by fostering expenditure and investment across different sectors of the economy. Similarly, for companies, whether they are small family-owned businesses or larger corporations, bank lending has traditionally served as the primary method for raising capital and is seen a fundamental strategy for growth and sustainability of such companies.

 

Despite efforts in recent years to diversify sources of capital, such as promoting a more robust capital market, the trend of bank lending as the primary financial source remains remarkably entrenched. While there have been numerous initiatives to simplify regulations and reduce costs associated with alternative sources of financing, the cultural and historical inclination towards banking institutions has been a tough pattern to break. Bank loans persist as the top choice for capitalization and funding in Portugal.

 

Small and midsize enterprises (SME’s) constitute the backbone of the Portuguese corporate landscape, representing an overwhelming majority, with more than 99 % of all businesses falling into this category. The issue of credit defaults and distressed debt is a notable concern for Portuguese SME’s, as the intricate nature of their business environment (cash flow inadequacies, fierce competition, rising operational costs, economic downturns, poor managerial financial literacy) and vulnerability to economic fluctuations drive them to struggle to meet their financial commitments. About 14.6 % of companies faced distressed debt concerning their banking loans in 2022.

 

Among individuals, in Portugal, the predominance of distressed debt concerning their banking loans reached a historic low of 7 % in 2022 (since 2009). However, credit default within consumers remains a matter of concern, signalling the ongoing need for vigilant financial management and regulatory measures to address potential risks. As a significant portion of individuals’ loans is tied to mortgages, this issue gains added importance, particularly when interest rates continue to climb, with no stabilisation foreseen on the horizon. Fluctuations in interest rates can lead to financial hardship and potential defaults. Ensuring that borrowers are adequately educated about potential rate changes and providing options for rate-lock agreements can mitigate these concerns.

 

Moreover, Portugal is one of the European countries in which non-performing loans (NPL) have a significant weight in relation to the total number of loans granted by national credit institutions, representing around 33 billion Euros as of December 2019. Given the substantial NPL ratio, the sale of NPL portfolios plays a significant role in Portugal, aligning with the European trend to reduce the level of indebtedness of European banks. This has led to an expansion on the size and complexity (both in terms of financial and legal architecture) of such transactions.

Understanding and addressing the main legal dimensions of debt lifecycle is vital for both creditors, debtors and third parties involved.

 

Within the dogmatics of Private Law, this research project embarks on a comprehensive exploration of credit debt throughout its entire lifecycle, encompassing critical stages such as Credit Default, Distressed Debt, Debt Restructuring, and Non-Performing Loans. The project aims to conduct a global analysis akin to a laboratory setting (hence Debt Lab), shedding light on the multifaceted legal dynamics surrounding banking credit debt.

 

Primarily rooted in banking law, this project adopts a structural approach to address the research questions. So it also explores the bedrock of civil law, the law of obligations, company law, and insolvency law, interconnecting and interrelating a diverse array of issues encompassed within these legal domains.

 

A unique outset marks the inception of this research project. Almost a decade back, following the aftermath of the 2008-2009 global financial crisis, the CIDP took a first step towards addressing the subject of banking debt and its lifecycle. The first strides were made through collaborative sessions involving academics and legal experts as part of the Post Graduate Course on Banking Law. This course has been held successfully every year. It is currently in its 9th edition.

 

Over the span of nine editions, the investigation into credit debt has deepened and broadened, mirroring the dynamic shifts in the social and legal context surrounding this subject. This evolution has been evident in the face of events such as the pandemic, as well as the onset of periods marked by a war and soaring inflation, followed by the rampant rise in interest rates.

 

It is now time to leverage such CIDP’s past accomplishments and advance on a comprehensive research endeavour focused on this subject. This research project seeks to produce new knowledge of credit debt by studying it as a complete lifecycle through an in-depth analysis.

 

To do so, the DEBT LAB will follow certain sequential steps:

(i) Mapping the credit debt lifecycle;

(ii) Examining the legal frameworks and contractual arrangements that govern credit debt at each stage – with primary emphasis on the Portuguese and European legal arenas, while actively engaging in legal discourse with other systems;

(iii) Comparing international practices and case studies to identify best practices, gaps, and opportunities for enhancing the Portuguese legal framework;

(iv) Evaluate the socio-economic and financial implications of credit debt and its various stages on borrowers, lenders, and the broader financial ecosystem – particularly with regard to individual borrowers;

(v) Identify and propose legal and regulatory strategies for mitigating risks associated with credit distressed debt, with a focus on preventing litigation and promoting out-of-court debt workouts.

More specifically, the DEBT LAB aims to address and explore, as solutions:

(i) Private autonomy and credit default: a critical dimension of this research entails the thorough examination of the parameters governing private autonomy in determining the outcomes of credit default situations. This comprehensive analysis encompasses contracts executed en masse under general contractual terms, as well as those meticulously negotiated on an individual basis;

(ii) Contractual clauses (comparison): contractual clauses relevant to credit debt, predominantly sourced from credit agreements governed by common law systems, will be examined. The aim is to appraise their appropriateness or inadequacy within the Portuguese legal framework;

(iii) Launching a “Debt Clause Library”: the aim is to launch a drafting tool and a library/ bible intended to introduce greater standardization in how Portuguese banks negotiate and agree clauses (in particular, on credit default) and assure that those clauses are valid and fair, thus avoiding subsequent problems in the credit relationship; the tool will set out standard drafting options for frequently negotiated credit default provisions, as well as the most common variants of these provisions;

(iv) Debt restructuring & struggling borrowers: the aim is to map the main legal problems which can hinder the success of debt restructuring or workout proceedings, aiming at analysing the extension of those obstacles and identifying solutions out-of-court that succeed on giving the debtor financial breathing room, which ensuring the collective interests of the creditors and guarantors. Close attention is paid to the extent to which Portuguese and European banks engage in debt restructuring to support struggling individual borrowers, and how did regulatory bodies oversee and guide these efforts; and

(v) NPL portfolios: the aim is to identify trends in Portuguese and Europe markets regarding the sales of NPL portfolios and then to clarify the legal and contractual architecture underlying such sales, by gauging the legal nature and the contractual design of the transactions (sale, mass credit assignment, securitisation or synthetic transactions), and thus seeking to reduce the level of legal uncertainty as regards the validity and legal compliance of said transactions. It also addresses the growing concern in Europe about abusive and aggressive informal debt collection tactics and practices towards vulnerable borrowers, in particular when third-party debt collection agencies are hired to recover NPLs.

The DEBT LAB project has concerns of a dual nature: (i) achieving a socially significant impact in a crucial area for the operation of the Portuguese economy, and (ii) engaging in and adding to the forefront of international legal discussions concerning matters related to credit debt.

Both rest on a shared core of research that involves:

(i) Mapping and monitoring of novel legal issues arising from an ever-changing economic reality, as well as the legislative and regulatory responses to govern them; and

(ii) Analysing the main and most pressing legal issues relating banking debt cycle, scrutinizing them within the framework of Private Law while maintaining a continuous dialogue with cutting-edge research and literature.

Both types of concerns, besides encompassing adjoining issues and resting on a shared core, have a synergistic relation between them.

Therefore, in addition to the core research activities, each of these concerns corresponds to a project phase.

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ESG Corporate Monitor

The matter of sustainability, in particular related to corporate governance and financial law, has been the subject of more extensive regulatory treatment, forcing companies to take into account the long-term sustainability of their activity. Therefore, there may be a conflict between profit maximization and sustainability, and administrators must act in accordance with the social interests of each company. In turn, regulatory requirements have been increasing, subjecting companies, investors and other stakeholders to challenges and realities in the field of sustainability.

 

Given regulatory growth, this will undoubtedly be one of the most relevant topics in commercial company law in the coming years, as well as one of the most interesting legal topics in the field of financial law.

 

The project will be divided into several phases:

(i) in the initial phase of collecting information on the incorporation of ESG factors in corporate management, the specific aspects to be analysed will have to be determined, but the aim is to analyse factors such as the existence of board committees specifically dedicated to sustainability issues, whether companies have initiated energy transition policies (depending on the sector in question), whether societies already integrate the Sustainable Development Goals, whether there are gender equality policies (in the case of obligated societies, whether these are limited to strict compliance with the law; in the case of others, whether they actually exist), whether there are inclusion policies, etc.;

(ii) this data will be processed and, subsequently, a report will be prepared with main conclusions;

(iii) efforts will be made to gather impressions from the market on the state of the art with regard to compliance with sustainability obligations, as well as how they have been integrating this complex reality;

(iv) organize, based on the aforementioned interactions, a collection of studies that allows determining the status quo, both from a transversal and a national perspective;

(v) following the launch of the aforementioned collection, organize an event with representatives or experts from various jurisdictions to understand the context and results of this recognition and regulation.

 

All these phases will be supported by a website created especially for this purpose, which will contain the various challenges in this matter and the project outputs.

The objective of this project is, in the initial phases already mentioned above, to analyse the way in which the issue of sustainability has been approached.

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Lisbon DAO Observatory

The emergence of blockchain technology (and other decentralized registration technologies) and its various applications has been felt in a wide range of areas of civil, commercial and financial law. One of the thorniest issues has been the response to the phenomenon of decentralized autonomous organizations (DAOs). DAOs (a non-peaceful term) constitute forms of human organization based on blockchain technology, in which several members pool funds (usually in the form of cryptoassets) to pursue a certain activity (not necessarily, but generally profitable) and whose government is largely automated and decentralized, which means that the traditional role of the management body is replaced by a mix of management by all members and automated management by a smart contract.

 

These new forms of organization, in their diversity, present unique challenges, but end up not operating entirely outside the law. The doctrine, national and foreign, which has already spoken out on the subject, ended up leading this form of organization back to more “primitive” societal phenomena, such as civil societies (or in collective names, depending on the legal system) in the Romano-Germanic systems or partnerships in Common Law systems. However, such qualification generally results in the absence of legal personality of these organizations and the unlimited liability of their members, an undesirable situation both for them and for third parties who use this form of organization.

 

Given the recent growth in the number of DAOs, it will be justified for the legislator, sooner or later, to intervene. Such an intervention will not appear easy, as DAOs present unique challenges to legal science, requiring the re-evaluation of many assumptions and models in force for decades. It will undoubtedly be one of the most relevant topics in commercial company law in the coming years, as well as one of the most interesting legal topics in the field of Fintech.

 

The project is divided into several phases:

(i) in the initial phase of gathering information and perspectives, we will seek to gather impressions from the industry (existing DAOs or associations) on the state of the art with regard to how DAOs organize themselves and respond to the various legal challenges of their existence, as well as receiving input from European academics and practitioners on how DAOs can be qualified in their law;

(ii) organize, based on the aforementioned interactions, a collection of studies that allows determining the status quo of DAOs in Europe, both from a transversal and a national perspective;

(iii) following the launch of said collection, organize an event with representatives or experts from jurisdictions where there is already some recognition of DAOs or similar structures (for example, Vermont, Wyoming and Malta) to understand the context and results of this recognition and regulation; and

(iv) through a conference and the publication of a final report, recommend some type of action to the European Commission with regard to the regulation of DAOs within the European Union.

All these phases will be supported by a website created especially for this purpose, which will explain the general concept of DAO and similar organizations and which will contain the project outputs.

 

The objective of this project is, in the initial phases already mentioned above, to draw a general framework of the legal status of these forms of organization in the law in force in various European legal systems, allowing the creation of specialized critical mass on the topic; and, at a later stage, be able, based on the information collected in the first phase, to make an important contribution to possible legislative responses to the phenomenon.

 

The topic has scientific relevance in that it forces us to rethink many basic principles of commercial company law (e.g., should limited liability always depend on the existence of legal personality? should limited liability always be associated with some form of delegation of powers from partners to administrators?). It is also related to the impact that smart contracts and their capital characteristic of self-execution will have on civil law and its fundamental principles.

 

The topic has public and practical relevance as the project aims to anticipate legislative and regulatory responses that should or could be given sooner or later. The project also seeks to provide the legislator – national and/or European – with tools for a proportionate and appropriate approach to the emergence of DAOs.

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Harmonisation and Unification of Contemporary Private Law

Private International Law, taken here as the discipline that includes jurisdiction, applicable law, international judicial cooperation and the recognition of foreign judgments, has been undergoing a process of intense harmonisation and unification in Europe and worldwide for several decades, carried out in particular through European regulations and international conventions, such as the HCCH 2019 Judgments Convention.

 

Such harmonisation and unification have proved invaluable in facilitating the mobility of people across borders and the international exchange of goods and services.

 

The process of international harmonisation and unification of private international law has, however, faced considerable challenges, largely as a result of the different national traditions that prevail in this area and its impact on sensitive matters of private law, especially those involving the regulation of family relations and inheritance.

 

On the other hand, the harmonisation and unification of private international law is taking place in parallel with projects to unify substantive private law, especially in international commercial law, either through international conventions or soft law instruments, such as, respectively, the United Nations Convention on Contracts for the International Sale of Goods, to which Portugal accessed in 2020, and the UNIDROIT Principles on International Commercial Law, and the coordination of these two key ways of bringing national laws closer together is not without its difficulties.

 

The aim of this project is to deepen the study of these processes and in particular their impact on the Portuguese legal system, where rules of private international law from domestic and international sources coexist and are not always easy to combine.

 

Among other things, the aim of this project will be to survey Portuguese case law applying the international and European instruments in question and identify not only the difficulties it has faced, but also the contributions it has made to the interpretation and application of these instruments.

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Publication of the English Translation of the Portuguese Civil Code

It has long been a quest of the CIDP to publish an English translation of the Portuguese Civil Code, allowing for its scientific dissemination across borders as well as its comparative study. Some preparatory work has already been carried out and the final revision is now being prepared, which should ensure that the legislator's intentions are reflected as much as possible, as well as the best options for translating purely national concepts.

 

As a proposal for a reliable translation of the Portuguese Civil Code, it is in line with the pursuit of its research line of contributing to the harmonisation and unification of Private Law, revealing the options adopted by Portuguese law.

 

The publication will include an introductory text that reviews the history of the current Civil Code and the various adaptations it has undergone to keep up with civil society, as well as its international influence.

 

The Portuguese Civil Code has an interest that transcends national borders and is an object of study in the various territories of the CPLP, spreading across four continents. It is cited by both the Principles of European Contract Law and the Draft Common Frame of Reference, emphasising its interest to an international platform of foreign researchers.

 

Its translation makes it possible to reach an audience wider than native Portuguese speakers, enabling the study of our law, its use in academic and professional contexts and, most importantly, its knowledge by all interested parties.

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Tradition and Globalisation in Contemporary Private Law

The processes of globalisation and multiculturalism have given rise to a movement of legal ideas that is constantly evolving.

 

The proximity of certain countries, which often share a common history, has inevitably led to the approximation of their respective systems, particularly through so-called legal transplants.

However, given the need to adapt each country's legislation to its recipients, its tradition and cultural roots, it is essential to contextualise it in the light of other sources of law and the unique reality of each human community.

 

In this way, despite the approximation of legal systems, whether through globalisation or the transposition of external influences, this reality has proved to be compatible with the preservation of tradition and customary law, particularly in African systems.

 

In fact, while the process of globalisation has been omnipresent, there is full awareness that it has been made compatible, shaped and conditioned by local contexts, customs and history.

 

To this extent, research into the way in which this compatibilisation has taken place over time, and especially more recently, is of great importance.

 

In this context, the annual meeting of the German-Portuguese Jurists' Association (Deutsch-Lusitanische Juristenvereinigung) was held in Lisbon on 16 and 17 September 2022, under the theme "Tradition and Globalisation", with the aim of bringing together thoughts, concepts and comparisons between Germany, Portugal, Brazil, Lusophone Africa and, indirectly, the African continent in general.

 

The Association of Luso-German Jurists is the leading association of German- and Portuguese-speaking jurists and aims to promote understanding of the legal culture of German and Portuguese-speaking countries, as well as interaction between them. In addition to Portugal and Germany, it includes Brazil, the Republic of Cape Verde, Guinea-Bissau, Angola, São Tomé and Príncipe and Mozambique, and also plays an important role in territories where Portuguese law plays an important role, such as Goa, East Timor and Macau.

 

With this in mind, the importance of this Association as a partner in this project is unquestionable, given its aim of promoting scientific work on important issues for the countries in question, namely through the organisation of lectures, conferences and the publication of scientific articles.

 

In this way, given the importance of the papers presented at the aforementioned meeting of the Luso-German Jurists' Association, the publication of a collective work entitled "Tradition and Globalisation: African, Brazilian and European Experiences" is of great importance.

 

The book will be published through a partnership between Almedina and Nomos Publishing, as the aim is to publish it simultaneously in Portugal and Germany, ensuring its internationality. The co-coordinators are Professors Dário Moura Vicente, Stefan Grundmann, Christian Baldus and Catarina Salgado.

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Civil Liability in Mass Relationships

Civil liability is an institute in permanent evolution. After the challenges brought about by the increase in dangers, the growing anonymity in social relations and the extension of production chains, the dogma of liability is faced with challenges arising from the fact that the same situation of liability originates from the actions of a (determined or undetermined) group of subjects and affects, in a homogeneous or heterogeneous way, a determined or undetermined group of injured parties. Bear in mind, in particular, the issues of uncertainty about the identity of the cause, the causal process and the identity of the victim. In addition, there is uncertainty about the amount of damage.

 

In mass relations, there are also problems linked to coordination between the institute of civil liability centred on imputation of damages - which has historically gained independence from criminal liability - and the sanctioning law of the regulatory authorities, which is purely preventive/deterrent in nature.

 

These lines of evolution thus justify a renewed look at classic problems of civil liability - such as (1) the function of civil liability, (2) causality, (3) the plurality of agents and/or injured parties, (4) the contribution of the injured party or parties to the damage, (5) the concept of damage and its determination or calculation, (6) the intervention of an idea of proportionality in calculating the compensation due, (7) the fate of the collectively established obligation to compensate, (8) the temporal dispersion of the harmful effects and their reflection in the system of limitation of the obligation to compensate, (9) the negative protection in mass relations (injunctive and eliminatory relief) -, based on the problems posed in the particularly complex context of mass relations.

 

In this light, environmental liability, liability in consumer relations, and liability for violation of regulatory rules (competition, banking, etc.) are particularly suitable fields of analysis, although not exclusive.

The project aims to confront ten different groups of civil liability problems in mass relations, always in the triple dimension of (1) analysing current Portuguese law (and, where appropriate, comparative law), (2) case law and (3) possible prospects for legislative reform:

  • The impact of situations of mass injury on the recognition of new roles/functions for civil liability;
  • Uncertainty as to who caused the damage (particularly when there is a limited number of potentially responsible parties: cases of so-called uncertain alternative causation);
  • Uncertainty as to the identity of the victim;
  • Uncertainty about the causal process;
  • Uncertainty as to the extent of the damage (particularly in liability for infringement of competition law)
  • Consideration of the injured party's contribution to the damage when calculating compensation;
  • The importance of the principle of proportionality in setting compensation;
  • The destination of the collectively established obligation to compensate;
  • The temporal dispersion of the harmful effects and their impact on the statute of limitations for the obligation to pay damages;
  • Negative protection in mass relationships (injunctions and eliminatory).

In the course of the research, other questions may be raised or, of course, those already identified here may be specified.

 

The issues raised are particularly relevant and topical. They form part of the fundamental core of the line of research in which the project is organised and require coordination with other CIDP lines of research, especially the "New Perspectives on Regulation, Compliance and Private Enforcement" line.

 

This project has a close thematic link with the project "Risk Society and Mass Society”. For this reason, a close link between the two working groups should be maintained during the implementation of both projects, which will be ensured in particular by the existence of four joint researchers.

 

The interdisciplinary nature of the topic of mass offences means that the line between it and the "Risk Society and Mass Society" project must be clearly defined. The present project (Civil Liability in Mass Relationships) deals exclusively with the (upstream) theme of the problems generated by mass relationships in civil liability. The "Risk Society and Mass Society" project is only concerned with procedural matters (downstream).

 

Consequently, the purpose of the two groups working together is to provide a framework for the collaboration that is indispensable, particularly given the well-known importance of substantive law solutions in defining and responding to procedural problems.

 

The co-operation of the two teams of researchers also ensures the strict separation of the thematic research work, both by preventing redundancies that generate inefficiencies and uncertainties and by obviating gaps that would otherwise arise.

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Gender Equality, MAP, Surrogacy and Multipleparenthood “MÉTIS”

The Family Law encompasses the fundamental social and legal core of society. It is from the family unit that social models emerge, replicated in various areas, as well as the affective structures that shape human development. This relational dimension of the family is in constant dialogue with the principles and fundamental values of the Legal System, from the principle of the dignity of the human person to the right to personality development.

 

However, the central nature of the family relationship does not render it petrified, immune to changes or intersections with other domains of human experience. Instead, family law has been a domain of great activity, especially in recent decades, with profound changes in social and affective relationship models, with evident repercussions in relational dynamics, in the role of women, in the exercise of parental responsibilities, and even on the very concept of family.

 

Additionally, we now witness the advent of the digital age and rapid technological development that compel us to reflect on new horizons, particularly in the realms of Family Law and bioethics.

In this regard, advances in genetics stand out, enabling the development of medically assisted procreation techniques (such as artificial insemination, in vitro fertilization, or the transfer of cryopreserved embryos), as well as the social and legal consolidation of realities such as surrogacy or single-parent families, elements with a transformative impact on the previously dominant family model, posing problems that Law must address, always mindful of the fundamental legal framework imposed by the Constitution.

 

As expected, sharp scientific and technological evolution has not always been accompanied by corresponding legislative adjustment, that cannot be carried out separated from ethical, moral, biological, sociological, and political considerations. The intersectional field invoked in this relationship assumes complex constraints, with personal and property-related echoes that need to be determined.

 

It is in this specific and complex domain that the purpose of the research project lies. Through an integrated analysis attentive to extrajudicial considerations, we aim to examine and discuss, among other topics, the evolution of the concept of family prompted by advances in MPA, the relevance of the principle of equality and the prohibition of discrimination in access to MPA, and multiparentality.

 

The scope of the principle of equality figures as a preliminary question in this context, inviting us to reconsider a set of issues in the field of filiation. Considering the complexity of family bonds and the plurality of vectors upon which they are structured, there is a demand to discuss the legal frameworks of surrogacy and legal motherhood (including the right of the gestational carrier to maintain a connection with the child) as well as reflections on the expansion of family models and the recognition of emotional bonds, particularly when in competition with biological bonds.

The globalizing drifts of the last century have compounded the problem, reinforcing the necessity to coordinate different legal systems, both regarding the use and access to MPA and the recognition of legal effects of such interventions abroad, particularly in the areas of fatherhood and motherhood recognition and the exercise of parental responsibilities.

 

Additionally, issues related to the position of the gestational woman arise [in the specific case of surrogacy], whom often is in a situation of great vulnerability and economic dependence, and for whom surrogacy may be the sole or primary source of provision.

 

Aware of the described problematic scaffold, the objective of the presented project is to raise the debate into possible contact with other Legal Systems, in an effort to define solutions and interpretative paths that allow us to respond to globalization and the blurring of territorial boundaries, which, as stated, often represent a serious infringement on the values inherent to the subject, to the detriment of the protection of the child's best interests and the principle of equality in Family Law.

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Law, Culture, Heritage and Cultural Goods

In keeping with contemporary times and the importance of an analytical framework based on the foundations of Law given that there is no, proprio sensu, duality between Law and Culture, what matters above all is the study of particular topics stemming from the protection and enjoyment of cultural heritage and cultural assets.

 

All of these themes require research produced by interdisciplinary teams drawing both on the field of Law and beyond, indeed, reflecting a particular characteristic of this new branch of juridical science. In effect, while concerns over the protection of cultural heritage have over the course of time been raised at the international level as well as the European Union and internal level of each member state with the resulting regulations now composed of norms and principles that govern the protection, preservation, enjoyment, dissemination and management of cultural goods, of no less importance is the private law perspective in terms of the rights of individuals, rights in rem, of contracts, guarantees and insurance policies.

 

Furthermore, the Right to Cultural Heritage needs constant dialogue with other fields of knowledge external to Law, including History, Architecture, Archaeology, Conservation, Restoration and Anthropology in order to leverage a globalised vision of the theme in question. Hence, aware of the diversity and multiplicity of questions relating to the benefit of cultural goods, we would set out the following themes and problems, of unquestionable contemporary relevance and notable complexity, as the scope for subsequent research:

 

1. Benefiting from Cultural Goods in a Democratic Society.

With benefiting corresponding to the idea of gaining some kind of advantage, enjoyment or pleasure from an object, from a good, cultural benefiting takes on a duality, even a twofold reality. In practice, just as artists may appreciate their works as the respective creators as may others, third parties, enjoy the object, this cultural good. We may therefore distinguish between two distinctive levels, two facets to cultural benefit. On the one hand, the benefit to the artist, the creator. On the other hand, the benefit to the third party, the individual, the publics that contemplate, visualise, enjoy the artistic object, the cultural good.

 

However, whenever the benefit to the artist interconnects with authorial issues, the public benefit elicits questions of unavoidable importance worthy of careful and close attention within the framework of this project. Thus, as the enlightenment philosophers theorised about Taste, as the Italian Penal Code of 1930 alluded to obscene objects, susceptible to offending decency, as the National Socialist archetype expanded the scope of degenerative, it remains equally true that other restrictions and different constraints have arisen in more recent times. Whether in terms of that designated as subversive art in Brazil or the repercussions of the #MeToo movement in the museums of the United States and the United Kingdom, this also extends to the controversy surrounding the Robert Mapplethorpe: Pictures exhibition at Serralves.

 

However, while we do not encounter in the legislation of European countries, for example in the Portuguese Framework Law for Museums, directives of an aesthetic, political, religious or ideological nature, but rather the demand for the promotion of responsible citizenship through the affirmation of museums as institutions open to society, it is no less true that there remain limitations on the enjoyment of cultural goods, especially museum reserve, bibliographic and archival objects. This framework extends to include themes as disparate as public access, specifically the price and opening times, as well as exhibition restrictions according to the directives of institutions, their curators or even the artists themselves. This particularly focuses on the level of access, the period of exhibition and the entrance price or the placing in reserve collections. Furthermore, other issues derive from protecting the integrity of the work, its substance, aesthetic orientations, the trends of institutions, curators and artists, incorporating the most appropriate conditions for protecting and conserving cultural goods. For example, even when works of art have been legally acquired, there is the need to ascertain whether artists or creators reserved the right to exhibit their works for themselves.

 

The functions of museums, libraries and archives are not limited to safeguarding the collective memory or conveying the cultural heritage to future generations. They also need to strive to address the concerns and fears of the dynamics underlying contemporary society. It is therefore logically worth evaluating the restrictions and limitations on enjoyment but, equally, the public service activities carried out by these institutions. This specifically extends to their interventions in acquiring the works of new artists and the restrictions as regards the breakup of public and private collections located within the national jurisdiction. Correspondingly, the scope of this topic extends to court decisions as regards leading collections and objects of art, specifically the Miró and Elipse collection as well as the more recent controversies surrounding the preservation of the Berardo Collection.

 

Furthermore, heritage protection, particularly classification and inventorying, contains the objective of fostering effective cultural benefits. In practice, while classification determines whether a good holds a priceless cultural value, inventorying involves the system surveying, updating and exhaustively detailing the cultural goods existing at the national level within the scope of their respective full identification. Hence, this includes classified objects or objects undergoing classification and as well as other goods that, while not deserving of classification, nevertheless hold civilizational and cultural value. Thus, this extends to the inventorying of public goods, both the objects owned by the state or other collective state entities, and the inventorying of privately held objects, in reference to the property and goods owned by private collective entities and individuals. 

 

In sum, there is, consequently, the need to ascertain the validity and consistency of the measures enacted to protect and inventory cultural goods as well as the restrictions and limitations on benefiting and, in general terms, the public service activities carried out by museums, libraries and archives so as to ascertain the effective extent of the cultural benefit as a structural objective for open and democratic societies.

 

2. Between the Restitution and Return of Cultural Goods

The problematic framework surrounding the restitution of cultural goods is anything but recent. Issues arose, for example, in the writings of the archaeologist Quatremère de Quincy when he took a stand against the appropriation of the cultural goods of defeated peoples within the context of the Napoleonic campaigns. We may also recall the many consequences of the conflicts throughout the 20th century: specifically, the contested acquisition of the Parthenon sculptures or the impressive collections of works of art illegally appropriated by both Soviet and German troops. In the latter case, the German constitutional court ruled in 1968 that the legal prescriptions corresponding to the Nazi period, specifically those that had legitimated the seizure of goods from enemies of the people and the State, no longer held any juridical value in virtue of their running counter to essential juridical principles . In turn, in 2009, the British parliament, within the scope of encouraging the restitution of objects looted or illegally appropriated during the Nazi regime, enacted legislation for the restitution of cultural goods. 

 

Furthermore, this takes into consideration the directives of the UNESCO Convention of 1970 and that of UNIDROIT of 1995. In practice, UNESCO opted to highlight the importance of restitution, stipulating the need for states to implement measures designed to confiscate and return on request by the state of origin, any goods looted from museums, civil or religious public monuments or any similar institution, located in the territory of another state. We may also point to the state obligations arising from subsequent material norms. Nevertheless, the universe of goods susceptible to restitution remains extremely limited. The scope extends only to goods robbed from a museum or a public, civil or religious monument or some similar institution located in the territory of another state. Due to the shortcomings of the UNESCO Convention, the UNIDROIT Convention set out to protect not only the interests of the state but also the individual persons harmed by the confiscation or theft cultural goods. Nevertheless, the UNIDROIT Convention is no uniform law and does not even provide a minimum set of rules of a legal nature. Instead, this references norms at the national level and attributes competences to state courts in terms of ruling on periods for the restitution or return of cultural goods.

 

In turn, the 2014/60/EU Directive of the Parliament and Council aimed at eliminating some of the restraints existing in terms of returning cultural goods. In these terms, the member states may undertake the restitution of cultural goods neither protected nor defined as national heritage and, furthermore, do not need to be included within any category or comply with limitations in relation to any particular duration or financial value. According to this Directive, member states should enact legislative that provides for restitution cases to lapse after a period of three years counting from the date when the competent central authority of the requesting state gained knowledge of the location of the respective cultural good and the identity of its owner or holder. Within the framework, attention turns to Law no. 30/2016 of 23 August that transcribes the Directive into Portuguese legislation. This highlights the principle of protecting cultural goods that attributes the Portuguese state with the duty of diligence as regards the material return of cultural goods originally from the territory of another member states from where the good was exported illegally, whenever so protected or defined by any member state as national heritage of artistic, historical or archaeological value.

 

Nevertheless, while there is an undeniable strengthening of the grounds for the restitution of cultural goods, we encounter another trend and not necessarily symmetrical or favourable. This references the return of cultural goods to the peoples of Africa and South America in the wake of the colonial era campaigns of appropriation. As is known, this subject rose to the top of the agenda following the Report into the Restitution of African Cultural Heritage (2018), written by the Senegalese academic Felwine Sarr and the French historian Bénédicte Savoy, under the sponsorship of President Macron. We would note that this Report expresses doubts about the extent of temporary restitution. Not only is this practice deemed ambiguous but also qualifies as an oxymoron. In effect, the conclusions stem from the idea that the term restitute means to return to the legitimate owner, for usage and enjoyment, with the inherent recognition of ownership over the good.

 

Within the scope of establishing the complexity around this theme, the Report announces the existence of over eighty thousand objects originally from Sub-Saharan Africa in the collections of French museums. Indeed, while a proportion of these objects stem from private donations, others came from mass looting, exploration campaigns and ethnographic or scientific missions. Hence, the Report advanced with relevant criteria for a mass restitution as well as a chronogram detailing the transfer. This stipulates the swift restitution of objects deriving from military campaigns; the functional work of military or administrative officials during the colonial period (1885-1960); the work carried out by scientific missions prior to 1960 and those resulting from restoration projects or loans that had extended over time. This also advocates for complementary research as regards objects integrated into French museum collections in the post-1960 period. Finally, there is the recommendation that French collections retain those goods acquired in a legitimate and documented fashion, or those acquired in the art market in full compliance with the directives of the UNESCO Convention of 1970.

 

While the document was greeted with some reservations and scepticism, the French parliament went on to subsequently approve legislation authorising the return of cultural goods originally from African states. Subsequently, the French government reached bilateral agreements with African states in order to bring about the return of some cultural goods. In turn, in June 2022, the Belgian parliament approved a law recognising the alienable nature of goods connected to the colonial past of the Belgian state and correspondingly determining the legal framework designed for the restitution and return of cultural goods. Furthermore, in the same year, Nigeria signed an agreement with the Federal Republic of Germany designed to return a significant quantity of works known as the Benim bronzes. Naturally, this subject has also risen up the Portuguese agenda in keeping with the important collection of objects sourced from the former colonies and held in the collections of museums and other cultural institutions. Correspondingly, there is a clear need to accompany this issue with particular care and attention, especially as regards the terms and conditions for inclusion in any eventual agreements for restitution taking into consideration the relevant legal framework for the protection of cultural heritage and the eventual need for subsequent corresponding alterations. 

 

3- Intangible Heritage and Tradition

While the UNESCO Convention for Safeguarding the Intangible Heritage was approved in Paris in October 2003, recognising not only the profound interdependence between intangible cultural heritage and its material counterparts but also the negative effects of the globalisation processes and the social transformation that may take place due to the lack of the appropriate means to safeguard intangible cultural heritage, we should recall that the Portuguese Republic not only ratified the Convention  but also approved legislation that established the juridical regime for safeguarding intangible cultural heritage . Thus, just as intangible cultural heritage derives from, and among others, the artistic expression of groups and communities, in events of a performative nature, social practices, rituals and sporting events, drawing learning and competences from both progressive and traditional techniques , the applicable regime is governed by the principles of prevention, equivalence, participation in transmission and accessibility . Furthermore, the policy for safeguarding intangible cultural heritage specifically integrates its promoting as a means of bearing witness to the identity and collective memory; the definition of norms, methodologies and procedures capable of defending such heritage; support for programs and project safeguarding oral traditions and expressions, artistic forms and expressions of a performative character, social practices and festive events, knowledge and practices related to nature and the universe of competences under the auspices of traditional processes, techniques and learnings; fostering scientific, technical and artistic studies as well as research methodologies appropriate to the effective safeguarding of intangible culture heritage.

 

Furthermore, beyond the object, principles and policies for safeguarding, what also requires attention is the applicable scope of safeguarding measures and legal protection procedures. In summary, the scope and restrictive powers of the juridical regime for safeguarding intangible culture heritage. In effect, this only considers intangible culture heritage as that deemed compatible with the national and international stipulations binding the Portuguese state in the field of human rights as well as the demands for mutual respect among communities, groups and individuals. We would add that this restrictive delimitation of powers is not unique to Portuguese law. Indeed, article 2 of the aforementioned UNESCO Convention, after maintaining that intangible heritage, handed down from generation to generation, undergoes constant recreation by communities, contributing to generating feelings of identity and continuity, then stipulates the obligation to take only into account that heritage compatible with the existing international human rights framework and those imperatives for mutual respect among communities, groups and individuals.

We therefore face an impressive restriction on the legal scope. In effect, beyond intangible heritage having to be constantly recreated by communities, eradicating that which falls into disuse and attributing intangible heritage only to whatever takes human rights and the mutual respect between communities and individuals into account. Therefore, we are to exclude such traditional rights and practices that violate human rights such as, and for example, female genital mutilation or the sacrifice of children and adolescents, gladiatorial fights to the death or other practices infringing on human dignity. In practice, alongside a static perspective on the protection of intangible heritage, there is a preponderant and overwhelming dynamic aspect driving harmonisation with the structural values prevailing in contemporary society. Correspondingly, according to Regina Abreu, in a study dedicated to commemorating the tenth anniversary of the UNESCO Convention on protecting intangible cultural heritage coming into effect, sought to dismiss the fossilisation of practices and expressions of a supposedly cultural nature. 

While the Convention does not explicitly refer to the animal kingdom, the restrictive and modernising prism certainly does not remain neutral. On the contrary, and as Scovazzi highlights, it is not by chance that there have been no applications attempting to register activities or practices, even if traditional, harmful to animal wellbeing as intangible culture heritage . There have been other incidents of controversy in various legal systems as regards whether specific practices involving animals take on a cultural nature. In Brazil, such issues became a constitutional issue in terms of cock and bull fighting as well as the vaquejada cowboy bull chasing tradition. In Portugal, this was the case with the recently prohibited shooting of pigeons and with bullfighting very much on the political agenda. In all these cases, tradition is clearly present alongside claims of a cultural dimension. There is the corresponding need to ascertain whether or not these traditional practices may be incorporated within the scope of intangible culture heritage. This naturally also extends to questioning other traditional practices that do nevertheless ensure animal wellbeing.

 

4- Memory, Culture and Heritage.

Memory has been present throughout the entire history of mankind. Not only does Memory constitute the awareness of times past but this also depicts a matrix of philosophical considerations of a gnoseological nature, featuring various aesthetic and artistic trends. There are also the historicist currents that contrast individual memories with collective memories, the memories of the conquerors and the memories of the conquered and in addition to voluntary memories and involuntary memories. This should also overlook neither the memories of techniques and technologies nor, and above all, the irreconcilable dichotomy between memory and that forgotten.  

 

However, while Memory establishes the mainstay between the past and the present, if it is also present in historiography, Memory then also provides a fundamental dimension of Human Culture. In practice, this accepts the existence of two types of memory, the communicative, focused on the recent past, and the cultural, constituted by the heritage bestowed by texts, monuments, artefacts, historical, artistic and archaeological objects, cultural goods, both tangible assets and intangible. Hence, as Jan Assmann recalls, cultural memory stretches back to the mythical times of origin, crystalizing experiences of the past and displaying a strong if inevitable interconnection with identity. Thus, cultural memory enables the tracing of a narrative image of the past all the while simultaneously deepening our own identities.

 

Beyond those denominated by the laws of historical memory, cultural goods play an undoubtedly high profile role within this identity focus. As we know, beyond the narratives, the historical accounts, the true Memory is found in the archives, the inventories, the libraries, the collections, the museums, the monuments, papers, materials, artefacts, in archaeological objects and their respective contexts prior and subsequent to excavation, discoveries or recoveries from the aquatic or subaquatic environments. Therefore, far more than any representation or historical reading, what matters is preserving, caring for and valuing Memory and Heritage. Furthermore, the right to memory and the preservation of the heritage and cultural assets belonging to distinct societies ends up strengthening the plurality of multiple identities, whether in terms of gender, ethnicity, religion, nationality or territory.

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Portuguese Civil Code – working papers

1) The problem and the project

Very often, legal texts are polysemic/equivocal; however, also very often, studies and previous versions of the published legal text clarify the meaning intended by the legislator. The project consists of making known the studies and the various versions of each of the 2334 articles of the current Civil Code (version published in the official gazette, 25 November 1966).

 

Example: There is the following major controversy over Article 11: which rules cannot be extended to similar cases? All exceptional rules, or only exceptional rules that go against fundamental principles? A comparison of the 8 versions (and their corresponding justifications) from 1948 to 1966 shows that the legislator meant all of these by the expression "exceptional rules".

 

2) Conditions for implementing the draft: recent access to more than 30,000 pages, more than half of which are unpublished

 

For decades, various jurists have tried to gather, organise and publicise these preparatory works (Albano Cunha, Rodrigues Bastos, Galvão Telles and Bigotte Chorão stand out). It's only now possible: the heirs of João da Matos Antunes Varela, minister at the time of the Civil Code and professor of law, have handed over the main documentary fund of this project to Menezes Cordeiro, retired professor and Principal Investigator of this project, and to the Torre do Tombo.

 

Menezes Cordeiro, representing the CIDP, and the Torre do Tombo agreed on a partnership, with the CIDP paying for the digitisation of the archive. This has already been done. This was followed by the delivery of small collections of documents from other prominent Civil Code authors (Inocêncio Galvão Telles, Fernando Pires de Lima, Paulo Merêa, Miguel Galvão Teles, secretary of the Civil Code drafting committee). The documents of the Civil Code's main workers have thus been collected (as the estates of Manuel de Andrade and Adriano Paes da Silva Vaz Serra have been lost). The last of these was delivered in 2023 (Paulo Merêa).

 

This was followed by: (i) an initial examination, by the Principal Investigators and some of the researchers working at the Torre do Tombo, of almost all of these 30,000 or so documents (more than half of which are unpublished), organising them into the major divisions of the Civil Code; (ii) the digitisation of all the collections; (iii) the preparation of the computer tools for the database mentioned below, to be set up online in a Teams environment; (iv) Menezes Cordeiro setting up the team for this project.

 

3) The project: legal and social relevance/relevance to the various lines of research within and outside the CIDP/relevance to the Torre do Tombo

 

It should be remembered that the Civil Code defines:

(i) The sources of law (and not just civil law – thus covering, for example, administrative, procedural and criminal law). In other words, it answers questions such as: does the judge look for the solution to each case in the legal texts? Or in customs? Or in previous judgements? Or does the judge create the solutions by making his own judgements?

(ii) How to interpret the legal texts: with the constraint of someone interpreting a doctor's prescription? Or with the freedom of someone interpreting a poem?

(iii) The rights and duties of people in all their relationships with each other: the status of minors, accompanying adults, civil liability, mortgages, purchases and sales, leases, mandates, powers of attorney, contracts, usucaption, condominiums, usufructs, marriages, filiations, adoptions, wills...

The examples given highlight the transversal importance of the Civil Code (whose relevance in the Portuguese legal system can only be equalled by that of the Constitution of the Portuguese Republic) for theoreticians, for practitioners and for citizens in general; both in the prevention and repression of illicit behaviour; both in property matters and in personal matters (in particular, for the protection of freedom). Consequently, the examples highlight the importance of elucidating the meaning of the words used in the 2334 articles.

 

4) Intended result: a database

 

All the documents (physically present in the Torre do Tombo) will be presented in a database hosted by the CIDP (with reference to the partner Torre do Tombo), open to all, free of charge, serving in particular legal researchers and legal practitioners (judges, public prosecutors, registrars, notaries, lawyers).

 

The database provides the following: (i) the published text of the 2334 articles; (ii) 1 click on each article brings up the chronological list of the respective versions; (iii) 1 click on each version brings up the respective studies/author/date; (iv) 1 click on the heading of the respective part of the Code brings up the studies relating to sets of articles (with a reference to these studies in each of the articles in that set); (v) easily expandable support by integrating new data (given the characteristics of the computer tools): if new documentary collections appear, if you want to add other fields, such as Doctrine and Jurisprudence on each article (or set of articles) of the Civil Code, if you want to follow legislative changes... (vi) adaptability to other legal diplomas, especially structuring diplomas of Portuguese Law (such as the Constitution).

 

5) Interdisciplinarity

 

Alongside the database, which serves today's everyday legal life, the project includes a historical component about how the Civil Code was received by Portuguese society and other countries at the time. Isabel Graes, from the aforementioned Iuris, will be in charge.

 

6) Recipients

 

The database is open to everyone, free of charge, and will be of particular use to legal researchers and legal practitioners in their daily lives: judges, in their judgements; public prosecutors and lawyers, in their procedural statements; registrars, in their registers; notaries, in their deeds, etc.

The database will also be publicised in the Portuguese-speaking community: both because parts of the Civil Code are in force in Cape Verde, Guinea, Angola, Mozambique and Macau, and because of the legal-scientific interest in the Civil Code on the part of many lawyers from Brazil who come to Portuguese universities for their postgraduate courses.

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Portuguese Jurists of the Ius Commune Period, I - 16th century

I. The Research Project aims to survey the Latin works of 16th century Portuguese jurists, many of them unknown in their content, which were the most relevant in their time in the area of Private Law, with a projection on subsequent scientific discussion, and which remain of interest for the knowledge of Portuguese and European Law today, as well as the translation and publication of two representative works selected from among them.

 

II. More than any other, Roman Law and, more directly, the so-called subsequent Romanistic Tradition, which occurred during the long period of ius commune, were decisive in shaping current private law. Many of today's legal solutions in Private Law, in crucial areas such as the Law of Obligations, Property or the Law of Succession, but also in the General Theory of Civil Law, were drawn up on the basis of historically delimited, tried and repeated schemes based on Roman Law and the Roman Tradition, which reached the codification period in the 19th century through its protagonists.

 

Without the study of these "vehicles", the understanding of such solutions cannot be complete, nor can a serious scientific study of law be made; without their study and consideration, the science of law today would become anhistorical.

 

The issue becomes even more acute if we consider that large-scale reforms of private law are being trialled and are on the horizon within the European Union, with a view to unification. The various working groups set up, initiatives and projects presented in the meantime are a prime example of this, ranging from the Unidroit Principles on International Commercial Contracts, the Principles of European Contract Law, the Trento Project, the Pavia Group / Accademia dei Giurisprivatisti Europei, Draft Common Frame of Reference - Principles Definitions and Model Rules of European Private Law (DCFR) prepared by the Study Group for a European Civil Code (1998) and the Research Group on Existing Private Community Law or Acquis Group (2002), and based on the revised version of the Principles of European Contract Law; more specific initiatives also exist, such as in Insurance Law, with the Principles of European Contract Law (2009/2015) prepared by the Project Group on a Restatement of European Insurance Contract Law (1999).

 

Acceptance of the results of these initiatives depends on the existence of common foundations between the laws of the member states; these foundations, when they exist, are to be found in Roman law and the Roman tradition; the history of law thus emphasises the international nature of legal phenomena in Europe. History plays a fundamental role in the construction of European law, as is well recognised. A fruitful example of the study and conscious use of the common bases and the European historical-legal acquis was in the field of buying and selling, in the 1980 Vienna Convention on the Contract for the International Sale of Goods (CISG), drawn up on the basis of historical-comparative work by Ernst Rabel, which would become a fundamental model for later initiatives, such as the aforementioned PECL or the DCFR, or for European Union legislation, such as the important Directive n.º 1999/44/EC on the sale of goods. 1999/44/EC on the sale of consumer goods and, mediately, in Directives 2019/770 and 771, which already include the sale of goods with digital elements and the supply of digital content.

 

Awareness of the historical formation of law is still absolutely essential in various areas of Private Law, and it is enough to think about how the gratuitousness of certain Romanesque contractual schemes, such as mutuum, mandatum or depositum, is still the basis of the corresponding regimes in the Civil Code. The same goes for the great unitary contractual type of locatio conductio, the understanding of which is crucial to understanding how it was tripartite in the medieval and subsequent schools and from there gave rise to autonomous contracts of enormous relevance, such as the works contract, the employment contract, the transport contract or the charter contract; contracts which, depending on the evolution that took place during the period of the ius commune, do not take on the same configuration in nearby legal experiences, such as the German, Italian, Spanish or French.

 

It is also necessary to take into account the persistence of certain solutions in current law, some of which in contractual types of enormous importance, such as the purchase and sale, which still has aspects regulated in nineteenth-century laws with a Romanesque basis (e.g. the purchase and sale of animals), the purchase and sale of animals) or which retains solutions, such as the one that still exists in terms of cancellation for non-payment of the price (Article 886 of the Civil Code), from the beginning of the 19th century that can only be seen in their break with the scheme of the Ordinances, the content of which was profoundly coined by the ius commune.

 

III. However, studying the works from the ius commune period that shaped the content of Private Law up until the 19th century codifications is arduous and only possible for a few. The overwhelming majority, especially the most important ones, are written in Latin. Some even predate the printing press in the 15th century and its generalisation in the 16th, and are therefore still in the form of manuscripts, the reading of which requires the aid of palaeography; others, although drawn up at a time when the printing press was already widespread, remained in manuscript form, many because they were drawn up in a university setting, without going to press.

 

In fact, although access to these works has been astonishingly facilitated in the last two decades by digitizing and making them available to the public via the Internet, the truth is that they remain little known and little worked on. The problem is even more acute in Portugal: in countries such as Germany, France, Italy, Spain, the United Kingdom and the Netherlands, relevant works by jurists from the ius commune period have been re-edited and translated, facilitating their access.

 

In Portugal, such an endeavour has been attempted in an unsystematic and fragmentary way, with only a few important works known to have been translated, many in the field of public law and political thought, and few of these with a critical and auxiliary apparatus. A survey, as far as possible exhaustive, of jurists and works from the period of the ius commune in Portugal has yet to be confirmed and completed: in addition to manuals, articles and doctoral dissertations on specific areas, there are some general repertoires that help with the task, but not all of them are specifically designed for the area of law, nor do they consider all the writings and versions that specialised studies have shown; in Brazil, the study of this period and its protagonists has also been done.

Therefore, on the eve of the second quarter of the 21st century, the vast majority of works by Portuguese authors from the ius commune period are still unknown or untranslated, if not, in the case of manuscripts, still to be published.

 

IV. The research project we have set ourselves has a very broad scope. Firstly, the period of the ius commune, even though it has various nuances, covers around seven centuries, from the 11th to the 18th, and has seen many protagonists. Therefore, in order to ensure that the project can be carried out within a foreseeable and reasonable timeframe, it is necessary to break it down into phases and limit it in time. Not because it is chronological, but because of the significant changes in perspective and method that Humanism imposed - even on those who remained faithful to previous methodologies - and, from a certain perspective, the considerable scientific "leap", both quantitative and qualitative, that took place during this time of transition: there is a greater number of known jurists and works; the training of Portuguese jurists and, in some cases, their professorship abroad is attested to; the press is generalized, with a greater dissemination of works; the density of research, which already takes into account the scientific acquis of previous centuries, increases; Portuguese law was consolidated with the publication, in the middle of the 15th century, of the "Ordenações Afonsinas" and, in the first half of the 16th century, the "Ordenações Afonsinas" (also presented as a time of transition, of rights being confined to national spheres, in which common law, especially Roman law, slowly but gradually became less relevant: This transition is also something that needs to be better understood and that micro-studies on jurists and their works will more easily allow).

 

It is also from this period, or more specifically from the 15th to 17th centuries, that the works of Portuguese jurists have had the greatest impact throughout Europe: Just think of Pedro de Santarém, whose treatise on insurance saw dozens of editions all over Western Europe; Aires Pinhel with his monograph on the rescission of purchase and sale; Álvaro Valasco with his study on emphyteusis; Jorge de Cabedo, António da Gama, Gabriel Pereira de Castro with their collections and jurisprudential commentaries; or Serafim de Freitas and his famous study in contradiction to Grócio, which would later involve Selden, on freedom of navigation on the seas.

 

There is already a very relevant set of known authors and works for the survey and selection, which, so to speak, have already been "pre-selected", facilitating subsequent work. The selection criteria will not always be easy and there are cases of transitional authors who lived between the 15th and 16th centuries and between the 16th and 17th centuries and whose works also oscillated between the two centuries.

 

On the other hand, the existence of canonists cannot be ignored, although they are not directly included in the following list, and the fact that many of them dealt in depth with private law issues. The nationality of the authors is also a problem: in the 16th century during the Philippine dynasty - and even before - the mobility between Portuguese and Spanish professors was remarkable; it will therefore be necessary to use a criterion that, while not rigid, allows for a coherent selection. There are also important jurists who taught but whose works are little known (Heitor Rodrigues (?- 1579); and there is also a significant set of manuscripts, which unfortunately is degraded (e.g. ms. 2745 BUC), with unexplored legal texts, possibly also by unknown authors.

 

The following is a merely perfunctory and illustrative list of some jurists and known literary production in the 16th century:

 

Luís Teixeira (147?-153?):

- In subtilem perutilem & necessarium digestorum titulum de rebus dubiis commentaria simul cum repertorio exactissime emendata (1507; 1531);

Manuel da Costa (1512? - 1563):

- Cap. si pater de testament. lib. sexto (Salamanca 1569);

- Commentaria in l. si ex cautione C. de non numerata pecunia, sc. adversus defendentem se hac exceptione - probandum actori esse numeratam pecuniam (Coimbra 1549);

- Commentaria in par. et quid si tantum leg. Gallus ff. de libe. et posthu. (Coimbra 1548);

- Commentaria in par. si arbitratu ... de conditionibus et demonstrationibus (Coimbra 1551);

- De acquirenda haereditate ff. l. 29 tt. 2;

- De suo et alieno posthumo commentaria in par. posthu. instit. de legatis in difficilem leg. si filius haeres D. de liberis et posthumis scholia (Coimbra 1552);

- In celeberrimas iuris Caesarei leges et paragraphos commentarii (Salamanca 1584);

- In nonnulas leges et paragraphos commentarii (Lyon 1564);

- Iuris Caesaris leges & paragraphos commentarii & de maioratu bonorum patrimonialium & de regni successione (Salamanca 1584);

- Selectarum interpretationum circa conditiones et demonstrationes et dies libri duo (Coimbra 1551);

- Omnia quae quidem exstant in ius canonicum et civile opera (Lyon 1576; 1584);

Aires Pinhel (1512-1563):

- De acquirenda possessione (BUC, ms. 2745);

- De collat. bon. (BUC, ms. 2745);

- De injusto rupto (BUC, ms. 2745);

- De legatis 2.º (BUC, ms. 2745);

- De in integrum restitut. (BUC, ms. 2745);

- Mille assertiones in Jure civili (Coimbra 1545);

- De bonis maternis commentaria, quibus materiae successionis jura feliciter explicantur (Coimbra 1557);

- Ad rub. et leg. II C. de rescindenda venditione commentarii (Coimbra 1558);

António de Gouveia (1510?-1566):

- Ad D. D. T. Senatusconsultum Trebellianum (reimpr. Paris 1864);

- Ad l. Gallum liber (Tolosa 1554);

- Ad l. X tit. ad l. Falcidiam (Lyons 1556);

- Ad tit. de vulg. et pupillari subst. (Tolosa 1554);

- De iure accrescendi liber (Tolosa 1545);

- Ex libro lectionum iuris variarum (Tolosa 1552);

- Lectionum variarum iuris ciuilis libri duo (Lyons 1561);

- Opera iuris ciuilis (Lyons 1561);

António da Gama (1520-1595):

- Decisiones Supremi Senatus Regni Lusitaniae (Lx 1578);

Álvaro Vaz or Valasco (1524-1593):

- Consultationum et decisionum, ac rerum iudicatarum (Lx 1588);

- Quaestionum Iuris Emphyteutici (Lisboa 1591);

- Praxis Partitionum et Collationum inter heredes (Coimbra 1605);

Pedro Barbosa (1530-1606):

- Commentarii ad interpretationem tituli Pandectarum de judiciis;

Francisco de Caldas Pereira e Castro (1543-1597):

- Tertia pars excelentissimo tractatus de Uniuerso Iure emphyteutico, complectens Eligendi, seu Nominandi ad emphyteusion potestatem, tam ex contractu, quâm vltima voluntate, & electionis reuocationem (Coimbra 1604);

- Analyticus Commentarius siue ad typum instrumenti emptionis, & uenditionis tractatus ... (1616);

- Tractatus de emptione, et uenditione, tum pragmaticis cum gymnastis ad modum utilis, ac necessarius diuque ab utrisque exoptatus nunc primum post auctoris orbitum in lucem prodit ... (1617);

Luís Álvares Nogueira (16th century):

- Repetitio ad rub. D. de legatis I (Lyons 1553);

- Repetitio ad Rub. D. De legatis I (cum comment. Emmanuelis a Costa, Si ex cautione) (Coimbra);

- Repetitio ad tit. D. de rebus dubiis (Lyon 1553);

Fernando Paes (16th century):

- Tractatus in forensi actione utilis de excusandis parentibus a publicis muneribus ob numerum liberorum (Lisboa, 1559);

Manuel Mendes de Castro (16th century):

- Ad celebrem Justiniani constitutionem commentarii (Salamanca 1587);

- De annonis civilibus libri XI Cod. singularis & noua repetitio, scholis & foro versantibus non inutili (Madrid 1592);

- Repetitio l. cum oportet VI de bon. quae lic. in potest. constitut. ex matr. (Augsburgo 1608);

- Practica Lusitana (Coimbra 1676).

 

The pre-selection of one or more works to edit does not seem simple. While it is true that researchers already have a pre-understanding of which of the known works and those they have already analysed make the most sense to edit on the basis of the criteria defined above, it is also true that in order to make such a judgment of merit with certainty, it is necessary to go through and get to know the content, relevance and size of all or a sufficiently large sample of the works in question relatively well, which at the moment remains to be done, and cannot even be achieved with the help of existing repertories.

 

This is one of the reasons why, instead of presenting a work already selected for translation, we opted for a more comprehensive project, with room for choice, which involves a prior survey. The other main reason lies in the timeliness of such a survey, given the inadequacy of those currently available.

 

It should be noted that recent studies have shown that there are more copies than were actually known and, among these, texts with appreciable potential: basing ourselves solely on the existing repertoires could therefore prove to be limiting and restrict the potential of this project and its contribution to the production of knowledge.

 

The present exploratory phase of this project will also be decisive and useful for collecting copies and selecting one of them, the most up-to-date and complete, for translation and editing. The results of the survey will be used to a large extent in the prefatory and introductory texts of each of the two books to be published. It is not possible at the moment to propose the publication of a stand-alone monograph with the results of the survey, since it would ultimately have to be extended over more than two years and to a larger number of libraries in various European countries, and given that previous, relatively recent attempts aimed exclusively at this endeavour, despite the expenditure of considerable effort and time, did not achieve such a result. The survey should therefore be seen as essentially exploratory and, to a considerable extent, its results can be used as part of the body of information to be included in the introductory studies of each of the texts to be published.

 

V. This research project will therefore involve, as detailed in the following section, a survey of the Latin works of 16th century Portuguese jurists, based on known repertoires and materials, and the selection, from among those identified, of two works by two different jurists, preferably one from the first and one from the second half of this century, the first from a printed edition and the second - accumulating the knowledge and method acquired from the first - from a manuscript, on subjects of Private Law, in specie the Law of Obligations, Rights in Rem or the Law of Succession, with repercussions on the subsequent discussion up to the present day, for translation and publication. In this way, an intangible, cultural, national but also genetically common, European heritage will be brought to light, which, in part, is yet to be discovered; and which, to a very large extent, even when it is discovered, its content is ignored or unknown, due to a lack of linguistic competences and skills on the part of today's jurists and, vice versa, due to a lack of legal competences and skills on the part of coeval philologists.

 

It is intended to be a project, in phases, but in continuity, with the intention that, on the basis of the experience accumulated in this first phase for the 1500s, it will be possible to move on to the following ones in the years that follow the realisation of the Project.

 

VI. The translation of a legal work cannot be done without a minimum understanding of the material problems involved, the models of solution or the discursive rules of the time in which the jurists wrote.

 

It therefore has to involve actively multidisciplinary work between jurists and philologists; multidisciplinarity and the pooling of efforts is not easy and is the reason why many Portuguese legal works remain untranslated. On the other hand, the survey, selection of works, palaeographic reading (when necessary) and Latin translation involve non-legal, philological and palaeographic knowledge, in which jurists are typically not proficient. The project therefore necessarily involves philologists, Latinists and palaeographers alongside jurists, so the team of researchers and consultants will have to be, as proposed, interdisciplinary, in partnership with CEC-FLUL and IVRIS.

VII. This research project is aligned with the guidelines of intergenerational balance and non-discrimination according to gender in the composition of the Principal Investigators, Researchers and Consultants.

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Risk Society and Mass Society: the new types of damage and the new morphologies of protection

(i) Content and relevance

This research project aims to deepen our understanding of the dogmatic and practical, procedural and substantive problems that arise in a society where the damage caused affects an infinite number of people and harms fundamental legal assets. Ecological disasters such as those resulting from the Mariana and Brumadinho dam collapses, along with the BP oil rig explosion, damage caused to consumers by practices that violate competition law, and the activities of large companies, both public and private, that are carried out in ways that run counter to the requirements of the legal order are just some of the examples in which the civil procedural response systems known in different legal spaces are proving to be inadequate and eroded.

 

This is why we have to face up to this great challenge: what new structures can be devised to provide effective protection for situations that have been violated and need to be compensated? What structures should be created to impose the adoption of behaviours that alter the way in which major social players operate?

 

The Portuguese legal system is the reference for an attempt to respond to all these challenges. However, the intention is to draw on the experiences of foreign legal systems, particularly those represented by the guest researchers. This communication is all the more relevant because it can, without exaggeration, be said that the world is divided into two blocs when it comes to finding answers to the problems identified: a Europe which, by tradition, conceives procedural systems based on an individualistic logic and which is beginning, even by imperative of the European Union legislator, to take the first steps in all these areas; and Brazil and the United States which, perhaps even because of their continental scale, have long since constructed a new general theory of procedure, capable of dogmatically explaining the models of reaction to the illicit offences that occur in mass societies and which sometimes appear as immeasurable damage.

 

A few more notes in this context; they make it possible to understand the absolute topicality of the issue and the urgency of finding answers. The development of societies since the second half of the 20th century has led to transformations in civil litigation. On the one hand, the intervention of the masses in legal transactions has proliferated, as has the growing juridicity of individual and collective life. Think, for example, of the rights of consumers, investors, students, sportspeople, etc.

 

On the other hand, the organisational model of companies consists of an agglomeration of structures, with varying degrees of complexity, built around a purpose or interest.

 

This is, after all, the characteristic of the human species that radically distinguishes it from others: the ability to build immaterial structures that bring together different members of the species around a common interest or in a community of interests. The fruits of this capacity have been accumulating since the dawn of time, with each present day being the pinnacle of its expression. Structures that in some cases, given their significant size, circulate in discourse under the name "system": the health system, the education system, the justice system, etc. But there are other structures which, although smaller in size, polarise and pursue ends that are of interest to many: for example, legal persons, especially commercial companies.

 

Because the components of the systems are interconnected and because elements with identical characteristics are repeated in the systems, it is not uncommon for a problem in one part of the structure to also occur in other parts of the structure. Collective protection is called for when the same legal problem occurs in different individual legal spheres. This circumstance raises the desirability, if not the necessity, of employing dispute resolution methods that are not confined to singular bilateral conflicts, but integrate the subjective plurality whose elements are, or may be, parties to objectively identical conflicts.

 

The responses available in the Portuguese procedural system, namely joint litigation and coalition, appear to be insufficient when the holders of the interests at stake are in the hundreds or thousands, or even indeterminable. The procedural challenges generated by this new form of litigation, known as "class actions", are multiple and cross-cutting. Just to name a few, there are the hesitations about jurisdiction, legitimacy and legal representation, the organisation of acts at the final hearing, the sentence and its effects, in particular res judicata, but also the admissibility of settling, withdrawing the claim or the case. And we can look in other directions, reflecting, for example, on the pressure caused by the protection of classes or categories of interests on the institutes of a substantive system that conceives of damages as compensation, which translate into difficulties in identifying and quantifying damages and in awarding damages to the various members of the category. This research project will pay attention to all these problems.

 

The structuring processes raise different problems, despite their affinity with those related to collective protection. Aimed at bringing about a change in the way a structure works, they have their origins in a 1954 decision by the US Supreme Court, which settled the case of Brown v Board of Education of Topeka. Following the refusal to enrol a black child in a public school attended exclusively by white children, the Supreme Court ordered the school to accept the child's enrolment. But the Supreme Court went one step further: having learnt, in a procedurally relevant way, that the school that had refused enrolment was not following an isolated practice, but rather was following a guideline common to several public schools in different states, it took advantage of the decision to order the public education system to change its practice, accepting both black and white children into schools without discrimination. With this decision, the Supreme Court, identifying a problem that cut across the entire public education system, issued a ruling with a structural effect. The category of structural proceedings was inaugurated, those in which the competent body issues an injunction ordering a change in the way a specific structure operates, either because it considers it to be illegal or because it considers that it does not follow best practice. Obtaining protection through structural proceedings is gaining ground. And the concept of structural proceedings is being extended to fields other than the one it was originally used in: today there is no doubt that proceedings that have an impact on the functioning of a structure - reorganisation of a company, protection of minorities in cases of M&A operations, bankruptcy proceedings or, more broadly, universal liquidation of assets - negotiations that affect a significant plurality of credits and debts of a specific subject, in a negotiated and extrajudicial context, are examples of what today is already classified as structural proceedings.

 

We are also interested in cases where immeasurable damage is caused. The Mariana and Brumadinho accidents, on the one hand, and the attacks of 11 September or the explosion of the BP platform in the Gulf of Mexico, on the other, prompt fundamental reflections on the compensation function of civil liability and the method of calculating damage. In the light of both groups of cases, the question must be asked as to the limits of liability law in its effective capacity to respond to a certain type of damage, which we have described as immeasurable damage. The "compensation through funds" mode raises the question of whether we are still moving forward with liability law, or whether we should instead develop a new language for these types of protection.

 

Finally, we will look at whether, and in what terms, arbitration can be used to obtain collective protection (class arbitration). The doubts are manifold: starting with the uncertainty about the need for the express will of the interested parties in the constitution of the arbitral tribunal, and ending, also for this reason, with the (in)efficacy of res judicata.

The problems posed by the object of the research proposed here are foundational, as they imply understanding and perhaps revising concepts and methods that occupy the essence of the protection of private interests. It is therefore closely related to the line of research in which this project is being carried out.

 

Each researcher, or groups of researchers that will be formed, will be assigned a specific problem area, on which they will carry out work that will have a conceptual or dogmatic dimension, but also a practical one, i.e. a study on the possibility, necessity and convenience of integrating the solutions developed into the Portuguese legal system.

 

(ii) Links with other projects in the same line of research

This project has a close thematic link with another, also proposed for the five-year period 2024/2029, entitled "Civil Liability in Massive Relationships". This link does not imply overlap or redundancy. Part of the problems dealt with by this project, namely causing immeasurable damage and compensating for it through funds, is at the heart of the "Civil Liability in Mass Relationships" project. However, as has been pointed out, not only is the affinity only partial, but it is also complementary in nature: while this project seeks to analyse the problem from a tendentially procedural perspective, the aforementioned project adopts an essentially substantive approach.

 

The demonstrated affinity and complementarity justifies cooperation between the researchers of both projects, which should be reflected in the joint carrying out of activities, but also in the synchronisation of the pursuit of research.

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Text, context and meaning in Private Law

The project is based on three different groups of questions.

 

1)    First group: The modern foundations of the contract’s interpretation.

 

The traditional doctrine of interpretation is based on the will of the parties and takes as its paradigm bilateral contracts of instantaneous execution. The reality is, however, much more complex and multifaceted. The increase in automatic and mass contracts in modern societies, many of them created by AI, the phenomenon of contracts born and concluded on digital platforms, and the existence of a significant intervention of third parties in the formation of the contract, for example, pose new questions to legal science: what is the basis of the vinculum? Is voluntas as determinant in the interpretative process as it was in the past? Does interpretation seek to discover the real will of the parties or is its scope rather associated with the protection of confidence and the sharing of risk? The criteria of interpretation set out in the Civil Code do not provide satisfactory answers to these questions: how should we deal with it? What are the practices observed in other jurisdictions historically linked to the Portuguese system (Germany, France and Italy, for example)? Is it possible to conceive a single method of interpretation or should we assume a methodological plurality, concerning the interpretation of normative texts?

 

2)    Second group: Contractual rules of interpretation

 

It is very common, especially in international contracts, for the parties to provide for various clauses on the interpretation of the contract itself. How should clauses dealing precisely with interpretation be interpreted? Are such clauses valid under Portuguese law? What are the limits of private autonomy in this area?

 

3)    Third group: Interpretation of the will of legal persons.

 

A very significant part of the legal transactions concluded in any jurisdiction has legal persons as parties, in particular, commercial companies. The knowledge and will of legal persons raise particularly difficult questions. If legal persons have no psychological or biological support, how can we establish a normative way of knowing something or wanting something? These questions are not new, but the impact of these issues on the formation and interpretation of contracts has not yet been studied. Should we apply the same hermeneutic criteria that we apply to the interpretation of contracts concluded between natural persons when legal persons are involved? If the answer is negative, which interpretation criteria should be observed? And which is the relevant jurisdiction: the law governing the contract or the personal law of the legal person concerned?

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The third party in the Law of Obligations: subjective complexity of obligations

The figure of the third party introduces great complexity into the legal relationship of obligation. In its most condensed form, the relationship pits only two people against each other (usually the creditor and the debtor) and that is enough.

 

The delimitation of the sphere of imputation of each subject is essential, right from this simple matrix. The obligatory relationship based on a "division of labour model" (and, within this, various relational paradigms) requires a different approach to the one that has been adopted.

 

Furthermore, within a broad sphere of relevant subjects, the delimitation of different levels of participation (and responsibility) in the obligatory relationship becomes more intense.

 

Finally, the figure of the third party, an element external to this fundamental relationship, implies a necessary adaptation of the system, which legal dogmatics tries to accommodate, step by step, with solutions based on a set of fundamental vectors. The role of private autonomy, good faith, trust and legal certainty are criteria, justifying a fundamental consideration of interests outside the primary scope of the obligation. The unveiling of this dogma, purifying any specific framework, either through the phenomenological analysis associated with it or by delving deeper into the basic institutes, corresponds precisely to the method that is seen as appropriate for exploring a topic that is generally lateralised by scientific research (national and international).

 

A comparative analysis of the solutions of other countries, both those belonging to the Roman-German Family and those of the Common Law, is essential. There is an essential bifurcation of the issue, depending on whether the intervention of the third party in the obligation bond is positive or negative, namely:

 

1. Delimitation of spheres of imputation

 

The use of forms of fulfilment based on a segmented and complex division of labour imply a new reflection on criteria of imputation, of acts and of subjective states relevant in the law of disorders of fulfilment.

 

2. Third party protection and due consideration

 

The precautionary function, of third party protection, underpins a vast set of solutions. From the outset, in the theory of the legal transaction, it involves investigating the prism of structural effectiveness (as is the case with the contract in favour of the third party and its dialectic), with avant-garde figures calling for strong doctrinal and judicial intervention (as is the case with the contract with protective effectiveness in favour of the third party). From a dynamic point of view, in other words, concrete issues arise in the execution of the obligatory programme, which test the limits of the system's sufficiency (e.g. the rules of appearance in representation or the third party's liability for non-performance), this time from the point of view of external effectiveness. On the other hand, the limits of the transmission of the credit (through lesser-known figures, such as the accession to the credit) or the personal nature of the institutes associated with the credit as a core legal situation are unclear.

 

As a centre of damage (reflex or ricochet damage), it is particularly difficult to adjust the framework, in particular to include in the sphere of compensation interests that do not belong to the sphere of the person who suffered the wrong (the same happens with fractional or collective damage). The same question arises in the context of fiduciary relationships.

 

The investigation of all the questions that this subject raises involves a comparative assessment of those that have been used by other legal systems, our counterparts.

 

3. Third party and third party liability

 

In a given situation of liability, the third party may also be liable to the injured party. In this context, the third party appears alongside the injured party. The need immediately arises to categorise the liability of these various parties, in a broad sense. The phenomenon of co-participation arises and others, such as instigation, appear alongside it. However, the proper treatment of this reality, which is specific to criminal law, cannot uncritically import solutions or terminology from another branch of law. The dogmatic autonomy of civil liability requires a different methodology. In particular, the clear absence of fundamental regulation of the liability of various agents (it should be noted) for different forms of liability poses serious problems for a system that classifies problematic liability under the same heading of liability (co-authors of the offence or defaulting co-defendants). The consideration, in a German proposal that is gaining increasing traction, of such, let's call it, imperfect solidarity, invites exploration of the issue in the most varied fields and domains (corporate relations, insurance law, family law, etc.). This is often the case with the liability of legal persons, who are materially incapable of acting in the natural world other than through subjects (third parties, from a certain analytical perspective).

 

Liability for the actions of third parties (the so-called vicarious agent, whether auxiliary or representative of the obligor) has also sparked heated discussion about the limits of liability independent of fault. The most recent proposals to create new areas of liability, such as fault for the organisation of legal persons, emerge from the perspective of protecting third parties in a structural relationship.

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Collective Investment Undertakings

Collective Investment Undertakings’ (CIUs) are institutions, with or without legal personality, whose purpose is the collective investment of capital raised from investors in accordance with a previously established investment policy. They comprise collective investment companies and investment funds.

 

CIU’s market is growing in Portugal, facing challenges and representing opportunities both to the market agents and to regulators.

 

CIUs are essential as corporate financing vehicles, providing a wide range of companies with the resources they need to develop their business plans. They are also central as an investment alternative for private and institutional investors who prefer not to take the risk of investing directly in target companies, but instead wish to invest in a professionally managed CIU that diversifies their risk by investing in a portfolio of companies.

 

In addition, CIUs are playing an increasingly important role in the transition to a more sustainable economy by implementing green investment strategies that individual investors cannot achieve on their own. All of this has helped to make CIUs an essential part and driver of the capital markets reshaping movement, at international and national level.

 

In this context, regulators seek to ensure an appropriate level of market and investor protection by regulating the inherent financial intermediation. In Portugal, the Securities and Exchange Commission (CMVM) has recently pushed for a renewed and simplified legal framework on asset management that was finally approved by Decree-Law no. 27/2023, of 28 April (the “Asset Management Regime” or simply AMR).

 

The AMR not only provides for new categories of CIUs and management companies, thus redefining the capitals market, but also creates new possibilities in terms of authorised investment activities, authorisation procedures, conflicts of interest, the issue of bonds or the marketing of investment units.

 

Despite their vital importance, CIUs have been overlooked by legal scholarship. The cries of market practitioners for clear guidelines on how to interpret, apply and enforce their legal regime have been ignored. To date there is not a single textbook, research book or monograph that covers this subject from beginning to end. Moreover, in respect to the vast majority of the issues, there is not a single line of text published.

 

Five years ago, the CIDP took a first step towards changing the status quo on this subject, by bringing together academics and practitioners to reflect on an array of topics, in the Intensive Course on Investment Funds. This course will see its 6th edition in late 2023.

 

It is now the time to build on what has been achieved so far and promote an in-depth research project on this subject. This research project will bring together national and international academics of different generations and experienced practitioners to produce new knowledge and offer the capital market a cross-sectional, comprehensive and in-depth analysis of the AMR, the relevant sanctioning provisions of the Portuguese Securities Code and the regulation model adopted in Portugal.

 

Major benefits may be obtained, not only from a theoretical point of view, but from a practical perspective as well.

 

On the one hand, by enabling financial intermediaries to better understand the applicable legal regime, it will allow them to better assess their compliance risks and reduce their compliance costs. As these costs are always passed on to their clients, the knowledge gained will also reduce the cost of investment for investors in general. In turn, such a reduction has the potential to lower the cost of capital for businesses, thereby stimulating economic growth and job creation.

 

On the other hand, it can also contribute to improve the efficiency and fairness of public oversight, the enforcement and compliance rules and procedures and implement better regulation policies.

 

The project team will focus on developing fieldwork to identify the main problems faced by market players (with APFIPP and other institutions), developing research at international level and producing a collective work (textbook) in English.

 

With regard to the latter, the idea is that each researcher will work with the principal researchers who will co-author each chapter of the collective textbook and ensure a cross-sectional dialogue.

The textbook is thus intended to be the result of collaborative research and intensive dialogue between the researchers, and not simply a compilation of articles written by each researcher individually.

 

The project will comprise 5 stages:

  1. An analysis of the law — covering both the law in the books and the law in action — in the markets most relevant to CIUs;
  2. A comparative law reflection based on step 1;
  3. An introduction to the pillars of European law that shape much of the legal regime governing CIUs in all Member States;
  4. A reflection on the fieldwork developed with APFIPP and other partner institutions to identify the main problems faced by market players;
  5. An in-depth discussion of the Portuguese AMR at three levels:
  6. The European Law applicable to each topic at stake;
  7. The Portuguese Law, in transposition/execution and/or beyond the boundaries of European Law;
  8. The enforcement system, with special focus on criminal law and on the law of administrative offences, within the broader “securities sanctions law” set forth by the Portuguese Securities Code.

International researchers will play a particularly important role in stages 1 to 3 and 5. In stage 4, the dialogue with partner institutions will foster a better interaction between theory and praxis.

 

The collective work will be publicly presented at an international conference and is expected to help shaping future courses and seminars offered by the CIDP and the FDUL on this subject.

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Corporate Responsibility in Comparative and European Law

Divided in three different phases, the project aims to analyse three interrelated and complementary problem areas which, in turn, are subdivided into the topics and questions identified below, the aim of which is twofold: to specify and delimit the initial problem areas; and to orientate the project towards innovative results and relevant outputs.

First problematic node: Prevention, detection, processing, investigation and sanctioning of corporate offence through enforced self-regulation, internal investigations, and responsive regulation?

Topics and issues to consider:

(i) Compliance programmes for preventive-repressive purposes and privatisation of public functions

Companies are required to have, or, at least, it’s convenient for them to adopt, compliance programmes aimed at preventing, detecting, and sanctioning (any) legal infringements typical of the activity carried out, the organisation and mode of operation adopted, the market or region in which they operate, etc.

These preventive-repressive compliance programmes involve granting private entities policing powers (which are often intrusive on the fundamental rights of employees, especially their rights to privacy and confidentiality of communications), as well as powers to conduct internal investigations (including of administrative/misdemeanor offences and even criminal offences), of processing, (disciplinary) sanctioning and civil reparation for the damage caused by internally proven offences.

(ii) Internal investigations, misdemeanor/administrative proceedings, and criminal procedure

In the case of administrative/misdemeanor and criminal offences perpetrated through the enterprise (and perhaps also against it), the granting of powers of processing, investigation and evidence gathering to private entities – powers which are currently constitutionally and legally reserved to public authorities – raises complex (and unresolved) questions about the relationship between internal investigations and misdemeanor/administrative proceedings and criminal procedure, including about the possible migration of information and/or evidence obtained in the context of corporate investigations and, moreover, in the context of a relationship between employer and employee, to such proceedings.

Among these issues, the following stand out.

  • Internal investigations, preservation of fundamental rights and the nemo tenetur se ipsum accusare of investigator and investigated.

Should internal investigations be carried out by the enterprise and/or by an independent entity? Which independent entity? Selected and paid for by the company itself? Which requirements must such an independent entity fulfil?

Can the evidence gathered by the independent entity, which independently co-conducts the internal investigations, be used in misdemeanour/administrative or criminal proceedings without breaching the investigated entity’s right not to self-incriminate or the attorney-client privilege regarding the offence in question?

Can the suspected or accused company use information and evidence incriminating its employees or managers produced as part of the internal investigation to defend itself in misdemeanour/administrative or criminal proceedings?

  • Legal regulation of internal investigations: recognition of pre- and para-investigations communicating with administrative/misdemeanour proceedings and/or criminal procedure?

Should internal investigations be legally regulated (who can direct and conduct them, in what cases, under which circumstances, according to which procedures?) and be subject to the fundamental guarantees of any sanctioning procedure, especially the presumption of innocence, the right to a hearing and defence, assistance by a lawyer, protection against self-incrimination and constitutional and legal prohibitions on certain means of evidence gathering?

If yes, however, would this lead to a problematic legal recognition of private pre-investigations and para-investigations, parallel to the misdemeanour/administrative proceedings or criminal procedures, which were once exclusively public, but now maintain a relationship of communicating vessels with the latter?

(iii) Compliance as a reward and a sanction for legal persons: the emergence of a Criminal Law and a Criminal Procedure based on the regulatory pyramid and responsive regulation?

In an effort to drive all legal entities to implement compliance programmes (even those that are not legally required to do so), the State has decided to reward companies as soon as they adopt such programmes, either before the offence is committed or during the criminal proceedings, and to punish them when they fail to do so until the delivery of the final decision.

The rewards can, for example, take the form of “suspension of the coercive measure”; provisional suspension of the criminal procedure through an order to adopt, amend or implement a compliance programme; special mandatory mitigation of the penalty; replacement of the fine with an alternative penalty.

In turn, the punishment consists of the imposition of an accessory penalty if, before the final decision is delivered, the legal person has not adopted and implemented a compliance programme suitable for preventing the commission of the crime or crimes of the same kind. This accessory penalty is a judicial order to adopt and implement a compliance programme aiming at the prevention of crimes of the same nature or, at least, at the significant reduction of the risk of their occurrence in the future. It may also be accompanied by the substitute penalty of judicial supervision.

The hypothesis of the present existence of Criminal Law and Criminal Procedural Law based on responsive regulation in relation to compliance by legal persons raises the following questions:

  • Does the outlining of regulatory compliance as a reward and punishment make sense also in misdemeanours/administrative law, in their respective procedure and in the sanctioning of companies/corporations?

Considering that the aforementioned rewards and punishments related to compliance programmes do not always find a parallel in administrative/misdemeanour offence laws, procedures and sanctioning, even at sectoral level, the perplexity intensifies. The natural field of application of responsive regulation and of the use of the regulatory pyramid is precisely that of administrative regulation, supervision, and sanctioning of economic activity.

Does this mean that, as far as legal persons are concerned, it is the already existing criminal law, but, above all, criminal procedure law, that is regulatory in nature?

  • Confrontation of the purposes of criminal penalties with the purposes of misdemeanour/administrative sanctions applied to enterprises/legal persons.

Criminal Law and Criminal Procedure, by focusing on the regulatory pyramid and responsive regulation in relation to enterprises/legal persons, force us to reflect on the true and specific purposes of the penalties applied to them: more orientated towards preventing future recidivism (special prevention) than towards punishing the crime committed by and/or through them (general prevention).

Is the special positive prevention of integration or socialisation of the legal entity/enterprise the primary purpose of the misdemeanour/administrative sanctions applied to it? Or are they – unlike the criminal sanctions applied to legal entities – essentially aimed at positive general prevention, reaffirming the validity of the administrative/misdemeanour rule that has been breached and at negative general prevention, intimidating potential offenders? What are the reasons for this?

  • Prevention of recidivism through socialisation as the primary purpose of penalties imposed on legal persons and legitimate purposes of penalties imposed on natural persons.

In the Criminal Law of a constitutional state grounded on human dignity, are there valid reasons why the sanctions imposed on natural persons, at least in economic criminal law, should not primarily aim at preventing future recidivism, through special positive prevention of socialisation, as is already the case in general with legal persons?

The fact is that the criminal law of a democratic state governed by the rule of law prohibits both retribution as the purpose of punishment and the instrumentalisation of the (human!) person to achieve any purpose, even a community one.

In other words: the confrontation with a Criminal Law and Criminal Procedure that are essentially regulatory in relation to legal persons, and therefore above all concerned with ensuring the future fulfilment of legal-criminal requirements by the specific collective entity, forces us to rethink the legitimate purposes of criminal sanctions against natural persons, not only in the context of economic Criminal Law, but in general. In fact, the liability of legal entities for offences provided for in the Criminal Code is not restricted to economic criminal law, but covers, for example, sexual offences.

(iv) Collaboration of offending companies with public authorities, opportunity in misdemeanour/administrative proceedings and criminal proceedings brought against them vs. preponderance of legality in the processing and sanctioning of non-business offences?

The privatisation of the functions of prevention, detection, processing, investigation, evidence gathering and repression of civil/administrative/misdemeanour and criminal corporate offences, the consequent opening up to new forms of collaboration between enterprises/legal persons and the public authorities and the proliferation of manifestations of opportunity in misdemeanour/administrative and criminal proceedings for business offences – all phenomena determined by the importance given to compliance programmes – require from us the reflection on the justification for the possible preponderance of the principle of legality in the processing and sanctioning of non-business offences.

Outside the realm of corporate offenses, administrative/misdemeanour and criminal in nature, isn't there also a case for making administrative/misdemeanour and criminal proceedings more permeable to new forms of collaboration with the perpetrators of offences and other expressions of opportunity on the part of the authorities?

Second problematic node: Enterprises, responsive regulation, enforced self-regulation and Private Enforcement: blurring of the boundaries between Administrative Law and Criminal Law and between Public and Private sanctioning? The emergence of a "hybrid" regulatory and sanctioning law: administrative-criminal and privatistic.

This problematic node is somewhat conclusive in relation to the problems discussed and addressed in the first node, and now brings up Private Enforcement, i.e., the private application of the law through collective protection actions (brought, in particular, by consumer protection associations or foundations or by associations of enterprises whose members consider themselves to have been harmed by the infringement) and actions for compensation for damage caused by corporate offences.

For the time being, Private Enforcement seems to be limited to national and European competition law offences (Directive 2014/104/EU and Portuguese Law nr. 23/2018). However, in Portugal, its regime should be articulated with that provided for in the broader Law nr. 83/1995 (Right to procedural participation and popular action). Both Directive 2014/104/EU and Portuguese Law nr. 23/2018 aim to solve problems and bring solutions that are not the prerogative of anti-competition offences, thus raising a problem of articulation of the respective regime with other fundamental diplomas such as the Civil Code and the Code of Civil Procedure.

Specification of the topics and issues of the second core of problems:

(i) Private Enforcement: concept and scope of application

There are several issues (interconnected with each other and with the previous problematic node) to be analysed and discussed in this area:

  • Is Private Enforcement effectively limited to anti-competition offences, or does it at least extend to offences against public health, consumer rights, quality of life, preservation of the environment and cultural heritage, by virtue of its coexistence with the broader right of popular action?
  • In view of this coexistence, is Private Enforcement restricted to actions for damages or does it extend to private (and only subsidiarily public – see Article 16(1) of Law nr. 83/95) claims for the prevention, cessation and prosecution of anti-competition offences, offences against public health, consumer rights, quality of life, the preservation of the environment and cultural heritage?

(ii) Relationship between Private Enforcement and Public Enforcement

  • How can (autonomous) actions for compensation for damages caused by business offences and/or private requests for the prevention, suppression and prosecution of these offences be reconciled with the respective prevention, processing, investigation, evidence and prosecution by the competent authorities? Private Enforcement as an alternative or rather a complement to Public Enforcement?
  • How can Private Enforcement be a tool for more effective economic regulation and more efficient self-regulation?

(iii) Private enforcement, responsive regulation, and evidentiary collaboration of the regulated and offending entities

  • Is it justified to limit the scope of the obligation to compensate and the subsidiary nature of this obligation in relation to the offender who has been exempted from a sanction thanks to the cooperation with the competent public authorities in detecting, processing, investigating, and proving an anti-competition offence (see Article 5(4) of Portuguese Law nr. 23/2018)?
  • How independent is Private Enforcement from Public Enforcement? Can Private Enforcement become an instrument of responsive regulation and evidentiary collaboration of the regulated and offending entities?

(iv) Blurring the boundaries between administrative law and criminal law: influence of ECtHR case law and repercussions on domestic legal systems

  • ECtHR case law: identification and discussion of leading cases.
  • Procedural benefits and risks for the control of the domestic legal decision to incriminate certain conduct and for the limitation of sanctions legitimately applicable under national law. The repercussions of ECtHR case law on the legal systems of the Member States, including constitutional case law.

(v) Blurring the boundaries and confusing the functions of public and private sanctions law: the influence of Anglo-American law and experience in Europe

  • Private Enforcement as an alternative and instrument of Public Enforcement?
  • Compensation for emergent damages and loss of profits as a sanction (and not mere reparation) for the misdemeanour/administrative and criminal wrongdoing of enterprises?
  • The emergence of a broad principle of opportunity in the processing and prosecution of misdemeanour/administrative and criminal offences against companies: non prosecution agreements or suspension misdemeanour/administrative and criminal proceedings in the law of EU Member States.

Third problematic node: Corporate liability in European sanctions law

Topics and issues to consider:

(i) Corporate liability in European law and in the case law of the CJEU and the ECtHR: identification and discussion of the main normative instruments and leading cases in European case law;

(ii) Drawing conclusions on the scope of application, prerequisites and criteria for imputing liability to legal persons or enterprises in European sanctions law, applicable sanctions and guarantees for their enforcement in and by the Member States;

(iii) Does a European sanctions law for enterprises/legal persons already exist, can it exist, and should it exist? 

(iv) Possible manifestations of self-regulation, responsive regulation and opportunity mechanisms in European sanctions law and procedure;

(v) Corporate Liability, Private Enforcement and Public Enforcement in European Law;

(vi) European Competition Law: the enterprise, the legal person or the personalised enterprise ("economic unit") as the subject of sanctions?

The problem in the national law, doctrine, and case law of the Member States (subject to the primacy of European law), in the case law of the CJEU and of the ECtHR.

Once again, a blurring of boundaries, confusion of functions and imputation criteria between public and private sanctions law?

Justification of the relevance of the project and links with the CIDP’s lines of research

The problematic nodes, and the topics and issues that concretise and delimit them are of undeniable relevance and practical topicality, not only domestically, but also in the fields of comparative law (EU Member States and the Anglo-American system) and of European sanctions law, and from both a lege lata and lege ferenda perspective.

The project therefore meets the fundamental core of the research line it is part of ("New Perspectives on Regulation, Compliance and Private Enforcement") and applies the respective methodology: analysing and reflecting on the state of the art, taking into account Portuguese, foreign, comparative and European experience, followed by the presentation of reform proposals emerging from these analyses and reflections.

The project is also related to practically all of CIDP’s research lines.

It is linked to the "New Perspectives on Corporate Governance" line of research, due to the topics of enforced self-regulation and responsive regulation, which presuppose an understanding of the company/legal person as an offender but also as an economic subject.

It maintains close links with the "Diversity, Harmonisation and Unification of Private Law" research line through the proposed study of Comparative Law, the attention it devotes to corporate liability in European sanctions law and to the influence of Anglo-American law and experience in Europe, promoted by the globalization of economy.

There are also strong links with the "Foundations of Private Law" research line, due to the topics of Private Enforcement and the relationship between Private Enforcement and Public Enforcement; the hypothesis of interpreting the evolution of legal systems in the sense of the blurring of boundaries, some confusion of the functions and criteria for imputing responsibility in Public Sanction Law and Private Law and the emergence of a "hybrid" Regulatory and Sanction Law (administrative-criminal and privatistic). The project also shares with this research line the methodology of critically analysing judicial activity and its impact on the aforementioned evolution of legal systems.

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Theoretical and Practical Judicial Evidence

At the Faculty of Law of the University of Lisbon (FDUL), the Theory of Evidence and Evidence Law have found a place in the programmes of some of the curricular units of the three Cycles of Study: Bachelor's Degree, Master's Degree in Law and Legal Practice (MDPJ), Master's Degree in Law and Legal Science (MDCJ) and PhD. 

 

In recent years, there have been important teaching offerings in Evidence Law, both in the civil and criminal fields. In addition to the Probation Law course in the MDPJ - Forensic Legal Sciences Speciality, the Criminal Procedural Law course in the MDCJ - Criminal Law and Criminal Sciences Speciality has, for several academic years, been entirely dedicated to criminal evidence.

 

With some annual variations, the programme has been specially designed to offer a global view of criminal evidence. For several years, the main researchers, Paulo de Sousa Mendes and Rui Soares Pereira, have been promoting projects on Evidence Theory and Criminal Evidence Law within FDUL and outside FDUL with other institutions and research centres, involving the publication of works.

 

First and foremost, the co-organisation of the III International Conference on Quantitative Justice and Fairness - Inference and Causality, in Lisbon, on 22, 23 and 24 May 2012, resulted in the co-editing, together with Vern R. Walker, Qing Pan and Rainhard Bengez, of the special edition of the journal Law, Probability & Risk, no. 3/4 (2013). I should also highlight my participation in the transnational research project of the Centre for Latin American Criminal and Procedural Law Studies (CEDPAL) of the Georg-August-Universität Göttingen, entitled "Fundamentals of Evidence Law in Criminal Matters", which began at the end of 2015 in Göttingen and met twice, in Lima, Peru, on 26, 27 and 28 September 2016, and in Ushuaia, Argentina, on 12, 13 and 14 October 2017, to discuss the texts subsequently published in two collective works by Tirant lo Blanch, one in Spanish and the other in Portuguese, respectively entitled Fundamentos de Derecho Probatorio en Materia Penal (2019) and Fundamentos de Derecho Probatorio en Materia Penal (2020). Finally, it is worth emphasising the book Prova Penal Teórica e Prática, published by Almedina in 2019, to which lecturers from FDUL, the Faculty of Law of the University of Porto and law schools in Brazil contributed.

 

In addition to these projects and works, Almedina published two volumes in 2020 and 2023 entitled New Challenges for Criminal Evidence, which include around 30 studies by students on FDUL's Master's in Law and Legal Science, who responded to the challenge of carrying out in-depth and comparative research on specific topics in the field of criminal evidence law.

 

In recent years, other projects have been carried out by these principal investigators in conjunction with researchers from other research centres and foreign universities, both in the field of Evidence Law in general and in the field of the interconnection of evidence with artificial intelligence. In this regard, it is worth highlighting the 2nd Quaestio Facti Workshop, coordinated by Jordi Ferrer Béltran, Kai Ambos and Paulo de Sousa Mendes, which took place at FDUL on 26 and 27 April 2022, as well as the International Workshop "Artificial Intelligence Applied to Law", coordinated by Luís Greco, Paulo de Sousa Mendes, Rui Soares Pereira and João Marques Martins, which also took place at FDUL on 20 April 2020.

 

Several modules of the Postgraduate course in Artificial Intelligence in Legal Practice and its Regulation, coordinated by Paulo de Sousa Mendes and João Marques Martins, have also been dedicated to the relationship between criminal evidence and artificial intelligence. The aim now is to take advantage of the knowledge and research experience accumulated in recent years, as well as the partnerships established with other Research Centres, Law Faculties and Universities, in order to fill a gap in the international and European context with regard to the systematic and comprehensive treatment of judicial evidence. Maintaining a theoretical and practical focus and continuing to encourage the use of the case method, the project aims to delve deeper into the subject of judicial evidence, with the participation of national and foreign researchers who have been dedicated to the subjects of evidence and evidentiary law for several years.

 

To this end, international events on current and complex topics of judicial evidence will be used for the researchers to present their research and collect contributions from the other participants to make improvements to their papers. The papers will then be published as a collective work and/or in a journal with double blind peer review. The publications will be in Spanish and English. Almedina's collection, New Challenges in Criminal Evidence, will also be continued with the publication of 4 new volumes.

 

Finally, a collective work will be prepared for publication by an international publisher, in English, with a view to providing a systematic and comprehensive treatment of judicial evidence without parallel in the continental European context.

 

The project will consist of 2 main phases.

 

Phase 1 is underway and comprises the following 5 sub-phases:

  1. Seminars on Technology and Evidence (online) and a final conference at FDUL (in person) - March 2025 (Lisbon), as part of Fundamentals of Evidence in Criminal Matters - Part Two;
  2. IV Workshop Quaestio Facti (University of Göttingen) 16/17 September 2024;
  3. Publication of the book Tecnologia e Prueba (in Spanish, by Tirant lo blanch, Spain);
  4. Publication of the articles from the IV Quaestio Facti Workshop, after double blind peer review, in English, in the Quaestio Facti Magazine;
  5. Publication of New Challenges for Criminal Evidence, Vols. III and IV, in Almedina, in 2024 and 2025.

Phase 2 includes:

  1. Publication of New Challenges in Criminal Evidence, Vols. V and VI, at Almedina, in 2026 and 2027;
  2. Preparation of a collective work, in English, entitled Treatise on Theoretical and Practical Judicial Evidence, with an international publisher (e.g. Springer, Nomos, Elgar, OUP).

National and international researchers will play a particularly important role in all phases and sub-phases. It is hoped that the work carried out will further promote the study of judicial evidence at FDUL and other Portuguese and foreign Faculties and Universities and will contribute to the creation of future CIDP courses and seminars on this subject.

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Research Lines

CIDP has decided to structure its activities for the period 2023-2028 according to five research lines, which will act as the basis for research projects to be developed, involving teams of rese...
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Master’s and PhD Scholarships

The scholarships awarded annually by CIDP aim to promote research in the scientific areas defined as main objects of study by the Centre’s Research Lines.
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