This article explores the evolution of the European Convention on Human Rights' applicability in private law through the development of the concept of positive obligations on states party. It explores the case law of the European Court of Human Rights primarily through the case of Pla and Puncernau v . Andorra, looking at the Court's willingness to review domestic courts' interpretation and regulation of private transactions. It considers the impact of this jurisprudence in the context of other doctrinal instruments emphasizing the consequent potential expansion of the Court's jurisdiction