L’obligation qui sert de base à la demande

L’obligation qui sert de base à la demande

  • Posted by Loïc Panhaleux
  • On 20 août 2015
  • 5782 Comments
  • compétence internationale, contrats, règlement 1215/2012

shutterstock_110112371La compétence des tribunaux en cas de contrats internationaux se détermine en premier lieu, conformément au Règlement UE n° 1215/2012 du 12 décembre 2012 concernant la compétence judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale, applicable depuis le 10 janvier 2015. 

L’article 7-1° dispose (a) qu’une personne domiciliée sur le territoire d’un État membre peut être attraite dans un autre Etat membre devant le tribunal du lieu où l’obligation qui sert de base à la demande a été ou doit être exécutée. Cet article prévoit donc une option de compétence par rapport à la compétence de principe, celle du domicile, prévue par l’article 4 du Règlement. Il suscite des difficultés d’interprétation et la jurisprudence est abondante. L’une des difficultés consiste à déterminer ce qu’est la matière contractuelle. Une autre consiste à déterminer ce qu’il faut entendre par “obligation qui sert de base à la demande”.

La question s’est tout d’abord posée de savoir si un même juge pouvait être compétent pour juger de deux obligations équivalentes découlant d’un même contrat. La CJCE a considéré que si deux obligations équivalentes doivent être exécutées dans deux Etats différents, un seul juge ne peut en connaître (CJCE 5 oct. 1999, Leathertex ; C-420/97 , Rec. CJCE I, p. 6747). Il n’en irait autrement qu’à condition d’admettre une compétence en fonction d’une obligation principale ( CJCE 15 janv. 1987, rev. crit. 1987. 793).

Ensuite, la question s’est souvent posée de savoir où localiser cette obligation servant de base à la demande. C’est le lieu d’exécution de cette obligation et non le lieu de la formation du contrat qui doit être pris en compte.

Le lieu où l’obligation qui sert de base à la demande a été ou doit être exécutée est déterminé conformément à la loi qui régit l’obligation litigieuse selon les règles de compétence de la juridiction saisie (Cass. com., 18 mars 1997, no 94-17.852 : Bull. civ. IV, no 74; Cass. 1re civ., 16 juill. 1998, no 96-11.984 : Bull. civ. I, no 252). Il ne s’agit pas de l’obligation caractéristique du contrat, ce qui avait été considéré dans un premier temps (CJCE, 6 oct. 1976 : DS 1977.616 ; Gaz. Pal.1977.1.100; Cass. civ., 23 janv. 1979 : Gaz. Pal.1979.1, somm. 247). Ainsi, dans le cas d’une demande de paiement d’honoraires par un architecte, la CJCE a estimé qu’il n’y avait pas lieu de retenir le lieu de la prestation de service (établissement des plans au domicile de l’architecte), mais le lieu du paiement, c’est-à-dire le domicile du client, en raison de la nature quérable de la dette (CJCE, 15 janv. 1987 : Gaz. Pal. 1987.1, somm. 283, obs. J. Mauro; en matière de paiement de commission : Com., 23 mai 1989 : Bull. civ. IV, no 159; Com., 12 janv. 1993, bull. civ. I, no 5; en matière de lettre de garantie fournie au profit d’une filiale domiciliée en France (Com., 3 mars 1992, bull. civ. IV, no 101). En matière de vente, il a été jugé que l’on doit rechercher quelle est la loi applicable aux obligations du vendeur, et si, au regard de cette loi, l’obligation de garantie est ou non distincte de l’obligation de délivrance, puis dans l’affirmative, quel est le lieu où doit être exécutée cette obligation de garantie (Cass. 1re civ., 9 févr. 1994, no 92-13.016 : Bull. civ. I, no 51Cass. 1re civ., 2 déc. 1997, no 95-20.809 : Bull. civ. I, no 341).

Pour la vente de marchandises, le règlement précise désormais dans l’article 7-1° b) que le lieu où l’obligation qui sert de base à l’action a été ou doit être exécuté s’entend du lieu d’un État membre où, en vertu du contrat, les marchandises ont été ou auraient dû être livrées. Pour la fourniture de services, il s’agit du lieu d’un État membre où, en vertu du contrat, les services ont été ou auraient dû être fournis.

Le texte laisse cependant aux parties la possibilité de prévoir une autre solution, ce qui présente l’inconvénient de leur permettre de fixer indirectement la compétence d’une juridiction sans avoir à respecter les conditions prévues par le règlement dans le cadre de la prorogation de compétence.

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