Views
New Rules on the Enforcement of Foreign Judgments in Saudi Arabia – Some Preliminary Observations
Many thanks to Karim El Chazli (Consulting and Testifying Expert on Arab Laws) for the tip-off
I. Introduction
The field of foreign judgments in the MENA region has witnessed additional legal developments. After Morocco, which adopted in February a new Code of Civil Procedure containing an updated regime for the enforcement of foreign judgments (see my previous on this blog), Saudi Arabia followed suit by adopting a new Execution Law (Nizam at-Tanfidh), approved by the Council of Ministers on 15 April 2026 (27–28 Shawwal 1447 H), which contains rules on the enforcement of foreign judgments. The new law replaces the existing Execution Law promulgated by Royal Decree No. M/53 of 3 July 2012 (13 Sha’baan1433 H).
Bahraini Supreme Court Accepts the Applicability of “Foreign” Jewish Customs in a Succession Case Involving Bahraini Jews
I. Introduction
This is certainly a genuinely interesting case from Bahrain, involving the application of “foreign” Jewish customs in a succession dispute that appears to be between Jewish Bahraini nationals. Although the case seems to lack any foreign element, its relevance to conflict of laws is nonetheless clear, since – to my knowledge – this is the first case in which the applicability of “foreign” religious customs in matters of personal status has been explicitly admitted in what appears a purely domestic case. The case also provides a broader analytical framework, raising questions about the place and applicability of non-state law in private international law (this contrasts of the recent decision of the French Supreme Court denying the applicability of Jewish law, albeit in a different context) and, more generally, about the compatibility of non-Islamic religious norms with domestic public policy frameworks in Muslim-majority legal systems.
Advocate General Emiliou’s Opinion on Case C-799/24: Res Judicata Effect Applies Despite Breach of Art 31(2) Brussels Ia
by Arvid Kerschnitzki, University of Augsburg
On 23 April 2026, Advocate General Emiliou published his opinion on Case C-799/24 – Babcock Montajes S.A. v Kanadevia Inova Steinmüller GmbH. It adds another piece to the puzzle that is the CJEU’s broad interpretation of the term ‘judgment’ in the Brussels Ia Regulation. At the same time, the case highlights the persisting problems with procedural coordination under the regulation.
News
African Review of International Law – Inaugural Issue & Call for Contributions
Many thanks to Boris Awa (Kigali Independent University ULK, Kigali, Rwanda) for the tip-off
The birth of a new academic journal is always good news, especially when its stated aim is “to become one of the leading scientific publications on international law” and when it is “primarily intended as a forum for African international lawyers’ reflection and research on issues of interest to Africa.” This is precisely the ambition pursued by the newly launched African Review of International Law (ARIL) / Revue africaine de droit international (RADI), published by the African Society of International Law (AfSIL).
European Civil Procedure Seminar, Leuven, 25 and 26 June 2026
The European Civil Justice Centre is pleased to announce a European Civil Procedure Seminar, which will take place on 25 and 26 June 2026 at the Faculty of Law and Criminology of KU Leuven.
The seminar is organised on the occasion of the publication of European Civil Procedure, edited by Xandra Kramer, Stefaan Voet and Adriani Dori, and published by de Gruyter in 2026. The book offers a comprehensive overview of the main developments shaping civil justice, including EU instruments on jurisdiction, recognition and enforcement, service of documents, taking of evidence, and collective redress.
Enforcing Indian Judgments Abroad: The Hidden Costs of Révision au Fond
A recent article in the latest issue of the Asian Journal of Comparative Law revisits a feature of Indian private international law that often sits in the background of transactional and disputes practice but can decisively shape outcomes: the continued presence of révision au fond in India’s law on the recognition and enforcement of foreign judgments (REFJ).