What is an interlocutory judgment (tussenvonnis) under Dutch law?

Dutch term: Tussenvonnis | Legal basis: Article 232 Rv

An interlocutory judgment (tussenvonnis) is a judgment that does not finally decide the case but orders an intermediate step, such as a witness hearing, an expert investigation, or additional written submissions. It is distinct from a final judgment (eindvonnis) which resolves the dispute.

Under article 232 of the Dutch Code of Civil Procedure, an interlocutory judgment is generally not subject to immediate appeal; the party must wait until the final judgment to appeal both. However, the court can grant leave for immediate appeal in the interlocutory judgment itself, and in some cases the party can request such leave.

Why it matters for international businesses

For international parties, an unfavorable interlocutory judgment (for example, one that shifts the burden of proof or orders an adverse expert investigation) can have significant strategic consequences even though it is not yet a final decision.