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Can a Seat Court Injunct a Foreign Non-Party to an Arbitration? Singapore High Court clarifies in Alphard Maritime v Samson Maritime (2025) SGHC 154

This guest post is posted on behalf of Kamakshi Puri, Senior Associate at Cyril Amarchand Mangaldas, Delhi, India, and dual-qualified lawyer (India and England and Wales).

The Singapore High Court recently clarified the scope of the court’s jurisdiction over foreign non-parties to the arbitration. In an application to set aside two interim injunctions, in Alphard Maritime Ltd. v Samson Maritime Ltd. & Ors. (2025) SGHC 154,[1] the court held that the the seat per se did not confer jurisdiction against non-parties to an arbitration, and that jurisdiction would first have to be established through regular service-out procedures before the seat court could grant an injunction against a non-party.

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AI in Arbitration: Will the EU AI Act Stand in the Way of Enforcement?

This guest post was written by Ezzatollah Pabakhsh, Master’s Student at the University of Antwerp

The European Union has taken an unprecedented step by regulating artificial intelligence (AI) through the EU AI Act, which is the world’s first comprehensive legal framework for AI governance. According to Recital 61, Article 6(2) and Annex III, 8(a), AI tools used in legal or administrative decision-making processes—including alternative dispute resolution (ADR), when used similarly to courts and producing legal effects—are considered high risk. These tools must comply with the strict requirements outlined in Articles 8 through 27. Read more

Clearly Inappropriate Down Under: Isaacman v King [No 2] and the Outer Limits of Long-Arm Jurisdiction

By Dr Sarah McKibbin, University of Southern Queensland

The Supreme Court of New South Wales’ decision in Isaacman v King [No 2][1] is the kind of case that tempts one to say ‘nothing to see here’, and yet it richly rewards a closer look. On a conventional application of Voth v Manildra Flour Mills[2] — the leading Australian authority on forum non conveniens — Garling J stayed proceedings that attempted to litigate a New York relationship dispute in Sydney, being ‘well satisfied’ that the NSW Supreme Court was a clearly inappropriate forum.[3] The reasons, though brief by design,[4] illuminate the transaction costs of jurisdictional overreach,[5] show how the Voth framework handles an extreme set of facts, and offer a careful case study for empirical debates about Australian ‘parochialism’ in jurisdictional decision-making. Read more

News

Virtual Workshop (in English) on October 8, 2025: Nadia de Araujo on “Highlights on the project for a Brazilian Law on Private International Law”

On Wednesday, October 8, 2025, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 11:00 a.m. – 12:30 p.m. (CEST). Professor Nadia de Araujo (Pontifícia Catholic University of Rio de Janeiro) will speak, in English, about the topic

“Highlights on the project for a Brazilian Law on Private International Law”

After more than eighty years Brazil finally has a project for a new Law on Private International Law. The current 1942 law devotes only seven articles to the whole subject. In light of the developments in PIL, the complexities of modern life and the adoption of a series of Hague Conventions and Inter-American Conventions, the project addresses PIL in its entirety. The new law introduces several significant changes: it expressly allows for party autonomy in international contracts, a concept that was not clearly defined in previous legislation, while safeguarding consumer and labour contracts. Additionally, it introduces new rules for proof of foreign law and a more comprehensive set of family law. It also retains domicile as the main rule for capacity and other family rights.

The presentation will be followed by open discussion. All are welcome. More information and sign-up here.

If you want to be invited to these events in the future, please write to veranstaltungen@mpipriv.de.

Conference: Towards Universal Parenthood in Europe, 24 October 2025

The University of Genoa (Italy), together with the partnership of the EU co-funded project UniPAR, is organizing a conference on parenthood in the light of Human Rights Law and Private International Law.

In the Conference, the UniPAR research team will present the results of the research and various topics related with EU private international law and children’s rights in the context of parenthood will be addressed. Dr. Raffaele Sabato, judge of the European Court of Human Rights, will deliver the introductory speech.

The Conference will take place on Friday 24 October, 10.00-13.00 CET and 14.00-17.00 CET.

See the programme. Online attendance is possible after prior registration.

AMEDIP’s annual seminar: Program and registration (in Spanish)

The program of the XLVIII Seminar of the Mexican Academy of Private International and Comparative Law (AMEDIP) has been published, click here.

To register, click here. Registration is free of charge (except if a certificate of attendance is requested). Only in-person participation is possible this year (with the exception of speakers, who may present online). Read more

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