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Judgment Mobility Rules in India’s Private International Law Regime: No place for a revision au fond?
This post was kindly prepared by Sai Ramani Garimella, Associate Professor, Faculty of Legal Studies, South Asian University.
A judgment-creditor is often concerned about the enforcement of foreign court orders, and that concern is not completely misplaced in India. The Supreme Court’s decision in Messer Griesheim v Goyal MG Gases is a useful illustration of the law governing the enforcement of foreign court orders and of the discussion of their finality and binding nature. Twenty-three years after the underlying loan transaction, and after much litigation, the Court has finally closed the chapter, refusing to enforce a 2006 English court’s summary judgment for roughly USD 5.8 million. Along the way, it has also clarified two recurring questions that often come up whenever a foreign money decree is sought to be executed in India:
Nothing to See Here: The CJEU’s Decision in Case C-232/25 Idzinski
Earlier today, the Court of Justice rendered its decision in Case C-232/25 Idzinski, essentially confirming its previous case law, combined with a restrictive reading of its infamous decision in Joint Cases C-509/09 and C-161/10 eDate.
The facts of the case (which was given the entirely fictitious name Idzinski) are eerily similar to those of the Court’s 2021 decision in Case C-800/19 Mittelbayrischer Verlag. Just like in that earlier case, they involved a claim by Polish claimants against a German media outlet regarding the correction of, and damages for, the publication of content that allegedly violated their personality rights, including their national dignity. Only two elements of the facts were different: first, the content complained of was broadcasted on television, in addition to being published online; second, the claimants were (1) a private person who was part of a Polish military unit during World War II, which the German broadcaster had allegedly portrayed as ‘anti-Semitic and nationalistic and as having collaborated with the Nazis in the Holocaust’, and (2) an association bringing together members of that unit.
After two decisions against the defendants (to varying degrees), the Polish Supreme Court had submitted two questions relating to the international jurisdiction of the Polish courts.
Refusal to Enforce in Egypt of a Californian (U.S.) Judgment for Lack of Reciprocity: What Has Gotten into the Egyptian Supreme Court?
I. Introduction
Sometimes, reading court decisions leaves a strange sense of confusion, especially when the decision rendered not only contradicts a well-established line of case law, but also when the court, in the very same decision, reveals internal contradictions. Several months ago, I critically discussed on this blog a rather unusual decision of the Egyptian Supreme Court (محكمة النقض/maḥkamat an-naqḍ), in which the enforcement of a Canadian judgment was denied on the ground that reciprocity had not been established with Canada. In my comments on that decision, I expressed “significant concerns” regarding the incoherent manner in which reciprocity was addressed by the Supreme Court.
News
JLMI – Call for papers – Issue no. 2/2027
The following call for papers has kindly been shared with us by the editors of The Journal of Law, Market & Innovation (JLMI).
The Journal of Law, Market & Innovation (JLMI) welcomes submissions for its second issue of 2027.
The Call for Papers for this second issue is devoted to European Regulatory and Supervisory Bodies in the Digital Realm.
You can find the call with all the details at the following link:
A NEW CONSTELLATION OF EU STATE REGULATORY AND SUPERVISORY BODIES IN THE DIGITAL REALM
Prospective articles should be submitted in the form of full papers to submissions.jlmi@iuse.it within 1 December 2026. The publication of the issue is set for the end of July 2027.
For further information, or for consultation on a potential submission, you can contact us by email at editors.jlmi@iuse.it.
Visit our website to read the full announcement.
Asian Conflict of Laws avant la lettre? Thảo Anh Hoàng, Early conflict-of-laws rules: Vietnam’s Lê Code (1483) in East Asian and global contexts
For those (like myself) who view private international law as we know it today as essentially a European invention of the 19th century it is fascinating to see examples of earlier and non-European regimes. One example is Article 48 (on ‘Infringements between peoples outside civilization’) of the Tang Code (653 CE) which reads: