PEETERS LAW ANTWERP & BRUSSELS - One cross-border legal practice
PEETERS LAW ANTWERP & BRUSSELS - One cross-border legal practice
Our Approach
At Peeters Law, we analyse legal problems not linearly but relationally. Jurisdiction, substantive qualification, normative constraints, language, legal culture and strategy are not approached sequentially, but read simultaneously.
For that purpose, we apply our own methodological framework — the Heptaract Approach (H7) — which approaches complex cases as dynamic configurations operating within several interconnected dimensions of legal reasoning.
The Penteract Model and the Heptaract Approach
Le terme Penteract désigne le noyau analytique de la méthode : cinq dimensions simultanément actives de l’analyse juridique, représentées par l’image d’un hypercube à cinq dimensions.
The term Heptaract, or H7, refers to the broader architecture of the approach as a whole: the Penteract supplemented by two meta-layers that render visible, respectively, the structural limits of the legal system and the analytical frame of reference itself.
These geometric references function as conceptual and mnemonic models rather than mathematical claims. Penteract designates the analytical core of the model; Heptaract designates the complete methodological architecture within which that core operates.
In Practice
In practical terms, each file is examined simultaneously through:
— five core dimensions: territorial (which court and which law), substantive (which legal rules and legal domains), language and legal culture, normative (fundamental rights, principles and hierarchy of norms), and strategic; — a sixth layer: structural fault lines and systemic limits within the law; — a seventh layer: reflexive examination of the analytical frame of reference itself.
This multidimensional perspective helps identify structural risks at an early stage, detect strategic incoherences, and approach complex cases with greater consistency, particularly in cross-border contexts.
Practical Organisation
Peeters Law handles files with Karen-Anne Peeters as permanent lead counsel and personal point of contact. The firm coordinates the file in accordance with this methodological framework and, where necessary, collaborates with specialised lawyers, academics and external experts. In this way, methodological coherence and targeted expertise are combined within a single integrated case strategy.
For those wishing to explore the theoretical foundations of this approach, a further elaboration follows below in dialogue with Savigny, Mayer and Heyvaert.
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Method
The Architecture of Legal Reasoning
An Outline of the Penteract Model and the Heptaract Approach in Dialogue with Savigny, Mayer and Heyvaert
I. From Linear to Simultaneous Legal Reasoning
Since Savigny developed the doctrine of the Sitz des Rechtsverhältnisses in the eighth volume of his System des heutigen römischen Rechts, private international law has largely been structured around the idea that every legal relationship containing a foreign element possesses a natural anchoring within a particular legal order. The task of the jurist consists in uncovering that anchoring and thereby identifying the legal order governing the relationship. The Savignian model possessed remarkable systematic clarity: legal relationships were conceived as objectively localisable relationships, while the conflict rule functioned as the instrument through which that anchoring became visible.
A century and a half later, that systematic purity has largely been relativised. The connecting factor has been pluralised, nuanced and, in certain fields, partially subjected to party autonomy. Under the influence of authors such as Pierre Mayer, the second half of the twentieth century also witnessed a shift from automatic conflict mechanisms towards a more differentiated approach in which the purpose of the rule, the object of the proceedings and the nature of the relief sought all contribute to the analysis.
Yet the underlying architecture remained largely intact. Jurists still frequently operate through an implicit sequential model: first jurisdiction, then applicable law, followed by qualification, and finally procedural and strategic implementation. The substance of the analysis has become richer; its underlying structure has remained largely unchanged.
It is precisely this structure of legal reasoning that is placed into question here.
A sequential model presupposes that each stage of the analysis can be completed before the next begins. In methodological terms, this is an assumption of independence: jurisdiction could supposedly be determined without anticipating qualification; qualification without regard to strategic positioning; strategy as the closing stage of an already completed substantive analysis.
Anyone seriously observing legal practice, however, immediately notices that experienced jurists rarely work in this way. They constantly anticipate. They revisit earlier stages whenever later elements reshape the analysis. The choice of forum often depends on the anticipated qualification; qualification depends upon applicable law; applicable law itself partly depends upon the connecting factor strategically defended.
Practice is recursive where doctrine remains linear.
This discrepancy between practice and doctrine does not constitute a plea for pragmatism against theory. It reveals a methodological lacuna. When actual reasoning operates recursively while the explicit model remains linear, an essential part of the analysis remains implicit. What remains implicit is difficult to test, transmit or criticise. The risk then emerges that legal reasoning degenerates into purely artisanal knowledge functioning only so long as its bearer remains present.
The Heptaract Approach begins precisely from that observation. It assumes that legal reasoning in complex cases is not truly sequential and cannot be sequential. The method therefore seeks to formulate an architecture in which that simultaneous and recursive operation becomes explicitly visible.
II. The Penteract Model
1. Five Simultaneously Active Dimensions
The analytical core of the approach consists of five simultaneously active dimensions collectively referred to as the Penteract. The reference to the five-dimensional hypercube is conceptual and mnemonic in nature: legal analysis does not unfold along a single direction, but within several interconnected dimensions operating simultaneously.
The five dimensions are analytically distinguishable but operationally coupled.
a. Territorial — This dimension concerns jurisdiction, applicable law, recognition and enforcement. It determines the coordinate system of the analysis: which court has jurisdiction, which law applies, and how a decision moves between legal orders.
b. Substantive — This dimension concerns the legal qualification of facts and their interaction across legal domains: contract law, company law, liability law, family law, succession law, property law, employment law, commercial law, procedural law and European law.
c. Language and Legal Culture — Legal concepts carry doctrinal and cultural meanings that vary depending on the legal order within which they operate. Concepts such as bonne foi, causa, trust or filiación activate different normative clusters depending on the legal order in which they are interpreted.
d. Normative — This dimension encompasses fundamental rights, constitutional guarantees, general principles of law and hierarchy of norms. It limits and reorients the possible directions of the other dimensions.
e. Strategic — The strategic dimension translates the interaction of the other dimensions into choices of action: litigate or negotiate, accelerate or delay, centralise or distribute, act publicly or discreetly. Strategy is not the closing stage of the analysis but operates simultaneously with the other dimensions.
2. Analytically Distinguishable, Operationally Coupled
The claim of the model is not that these dimensions are new. Each already exists within doctrine and legal practice. The core of the model lies elsewhere: in the proposition that their mutual orientation must itself become the object of analysis.
An analysis operating exclusively through one dimension while treating the others as external factors misses precisely what characterises complex legal reasoning: the dimensions continually recalibrate one another.
The dimensions are therefore not independent in the sense of isolated variables. They are analytically distinguishable as questions but coupled in their answers. A shift within one dimension alters the space of possibilities within the others.
Convergence between dimensions — for example where jurisdiction, applicable law, qualification and normative limitation all point in the same direction — generally indicates structural stability within the file.
Divergence, by contrast — for example where a procedurally strong position proves strategically disadvantageous, or where a substantive argument is normatively constrained — constitutes an early signal of structural risk.
3. The File as Dynamic Configuration
Together, the five dimensions form a multidimensional analytical space designated as:
𝒫(T, M, N, C, S)
where T denotes territorial context, M substantive legal domains, N normative structure, C culture and language, and S strategy.
A file does not remain statically positioned within this space but moves through it. New facts, case law, evidentiary developments and strategic choices continuously modify the configuration of the file.
The file may therefore be conceived as a trajectory:
D(t)
namely file D at moment t.
The model does not purport to offer a mathematical operationalisation of legal decision-making. The notation merely serves to render the relational and dynamic structure of the analysis visible.
III. The Sixth Layer: the Heyvaertian Singularity
However rich it may be, the Penteract Model remains a bounded analytical system. Not every file can be brought to a stable orientation within the five dimensions.
Where several legal orders simultaneously appear applicable without a clear rule of priority, where constitutional, European and national law together create a deadlock, or where jurisdictional rules overlap without hierarchy, structural instability emerges within the analysis.
The singularity is not a property of the law itself; it marks the analytical point at which the existing normative framework no longer permits stable coordination of the relevant dimensions.
It is here that the work of Alfons Heyvaert (1937–2024), emeritus professor of family law and private international law at the University of Antwerp, becomes methodologically decisive. In Met rede ont(k)leed, Heyvaert analysed legal categories as simultaneously ordering and limiting: they make legal reasoning possible while at the same time carrying internal tensions that become visible once analysis proceeds with sufficient depth.
For Heyvaert, rendering those tensions visible did not represent a failure of analysis but its completion.
The Heptaract Approach adopts that insight in the form of a sixth layer: the diagnostic identification of structural fault lines within the legal system itself.
The identification of a fault line does not signify the end of analysis but the beginning of another order of argumentation. It activates different instruments: preliminary references, constitutional review, principled appellate reasoning, parallel proceedings or coordinated legal development.
The classical public-policy exception corrects an outcome produced by the system. The singularity, by contrast, marks the point at which the system itself can no longer generate a stable outcome.
IV. The Seventh Layer: Reflexive Examination of the Frame of Reference
Above the Penteract and the diagnostic layer operates a final level of analysis: the reflexive examination of the analytical frame of reference itself.
Every legal analysis presupposes a legal culture, a normative hierarchy, an institutional position and a language of interpretation. These conditions remain implicit within much legal reasoning.
The reflexive layer seeks precisely to render those implicit conditions visible.
A file analysed from a Belgian civil-law perspective will not necessarily possess the same analytical structure as the same file viewed through Spanish foral logic or through a European fundamental-rights perspective. The facts remain unchanged, but their legal appearance shifts fundamentally.
Reflexive examination therefore does not imply relativism. It simply means that the jurist also makes their own analytical position part of the object of analysis.
In cross-border cases, where legal cultures, languages and normative traditions structurally diverge, this reflexive attitude is not an intellectual luxury but a methodological necessity.
V. The Heptaract Approach
The Penteract Model, the diagnostic layer and the reflexive layer together form a single coherent methodological whole: the Heptaract Approach, or H7.
The reference to the seven-dimensional hypercube is once again conceptual and mnemonic. The Heptaract is not a mathematical model but an architecture of legal reasoning composed of three distinct levels: structuring through the Penteract, boundary-detection through the diagnostic layer, and recalibration through the reflexive layer.
The method positions itself in dialogue with three doctrinal traditions.
With respect to Savigny, it preserves the idea of a legal coordinate system while rejecting the notion that such positioning objectively reveals itself to the jurist.
With respect to Mayer, it generalises the reflexive movement contained within the distinction between rules and decisions.
With respect to Heyvaert, it formalises the willingness to render structural tensions visible where further systematisation no longer provides clarification.
The approach does not claim originality in its individual elements, but rather in the architecture that brings these elements together within one coherent analytical framework.
VI. Conclusion
The Heptaract Approach does not provide a decision-making algorithm and does not replace substantive legal expertise. What it seeks to render visible is what often remains implicit in complex legal reasoning: the simultaneous interaction between jurisdiction, qualification, normative limitation, language, legal culture and strategy, as well as the structural limits and frames of reference shaping that interaction.
What it does offer is a working framework within which a file can be read, discussed and defended without losing its structure — a quality of practical importance in cooperation with fellow counsel, in-house counsel and foreign advisers.
Ubi ius, ibi remedium.
For intake, collaboration or referrals: info@peeterslaw.com
Peeters Law
Jos Smolderenstraat 65, 2000 Antwerpen, Antwerp, Belgium