Questão jurídica principal
Whether the action was a petition of inheritance or a contractual claim and which law applied
Decisão extraída
The claims were contractual, based on mandate, not inheritance claims; therefore Swiss law governed the contractual relationship.
Fundamentação extraída
The claimant did not seek to reclaim an asset in the estate by virtue of a preferential hereditary title, but to enforce the deceased mandator’s contractual claims. The inheritance convention governs the succession, but not the legal basis of these claims.