Italian torpedo
The Italian Torpedo is a private international-law idea used to slow down a dispute by filing in a country with long court delays, such as Italy or Belgium. The term was coined by Mario Franzosi in 1997.
How it works: The Brussels I-bis Regulation (Regulation 1215/2012) includes Article 29 on lis pendens. It says that if two courts in different EU states hear the same case between the same parties, all courts except the first one seized must pause the proceedings until the first court decides its jurisdiction. This makes it hard to pursue multiple lawsuits in different countries at once.
What the European Court of Justice says: The ECJ emphasizes mutual trust between member states and has limited ways to block a torpedo. This trust is considered more important than countering a torpedo through other means.
Exceptions: The tactic does not apply when a court has exclusive jurisdiction, such as cases about rights in rem in property or entries in public registers, under Article 24 of Brussels Ibis.
Change in 2012: To stop this tactic when there is an exclusive-jurisdiction agreement, Article 31(2) was added. This prevents using the Italian Torpedo if the parties have a forum-selection or similar exclusive-jurisdiction clause.
Brexit effect: Since the UK left the EU, Brussels I-bis no longer applies to many UK-related cases, and the tactic has reappeared for agreements governed by English law.
This page was last edited on 3 February 2026, at 19:21 (CET).