On March 15, 2018, the European Court of Human Rights (ECtHR) ruled [3] in Naït-Liman v. Switzerland that Swiss courts were not obligated to take up a case involving a Tunisian man who alleged that he was tortured in Tunisia in 1992, and that there was no violation of Article 6 § 1 (right of access to a court) of the European Convention on Human Rights. The case concerns a Tunisian national, Abdennacer Naït-Liman, who alleges that he was detained and tortured in Tunis on the orders the then Minister of the Interior, A.K., and was later granted political asylum in Switzerland in 1995. In 2004, Naït-Liman lodged a claim in a Swiss court for damages against Tunisia and A.K., which was declared inadmissible, and he later appealed to the ECtHR. As stated in the press release [4], the ECtHR reviewed state practice concerning universal jurisdiction for acts of torture and found “that the prevalence of universal civil jurisdiction was not yet sufficient to indicate the emergence, far less the consolidation, of an international custom which would have obliged the Swiss courts to find that they had jurisdiction to examine Mr Naït-Liman’s action.” The Court also found that international law did not imposed an obligation on Swiss authorities to make a forum of necessity—exceptional jurisdiction that a state’s civil courts assume where proceedings abroad prove impossible—available to Naït-Liman as there was no international custom rule on the matter, nor was there an international treaty obligation for states to provide a forum of necessity.  The Court also emphasized that this ruling “did not call into question the broad consensus within the international community on the existence of a right for victims of acts of torture to obtain appropriate and effective redress, nor the fact that the States were encouraged to give effect to this right.”