Conflict of laws – Jurisdiction. In a case concerning litigation between JSC BTA Bank and its former chairman's son-in-law (K), the Supreme Court found that, among other things, contempt of court, in the form of breaches of court orders, qualified as unlawful means for the purposes of that tort. In dismissing K's appeal, it further held that the case fell under art 5(3) of the Lugano Convention, namely.