French Supreme Court ruling: Avoidance claims are governed by the lex concursus

In two rulings on 2 October 2012, the French Supreme Court (Cour decassation) made clear that, outside the scope of the European Insolvency regulation and pursuant to French international Law, instead of using French Insolvency law to abide to actions of avoidance in foreign insolvency proceedings, these must be subjected to the law applicable in those Insolvency proceedings.