Key legal question
Whether Swiss courts had jurisdiction over the payment claim and lien claim in this international dispute.
Extracted holding
Swiss courts in Valais were competent: the Lugano Convention did not apply, the place of performance for the money debt was O., and the chalet’s location gave jurisdiction over the lien action.
Extracted reasoning
The defendant was not domiciled in a contracting state, so the Lugano regime did not govern. Under Swiss conflict rules, the claimant’s seat and the obligation’s place of performance pointed to Valais; the mechanic’s lien is a real right and must be litigated where the immovable is located.