Views
Book Review: Choice of Forum Clauses in Asia (Lemuel L Lopez)
Choice of forum clauses are an important means of managing litigation risk in international commercial contracts. Their effectiveness, however, depends on how courts understand and enforce the parties’ agreement. This well-researched book offers a substantial comparative examination of that problem across seven Asian jurisdictions: Singapore, Hong Kong, Malaysia, the Philippines, China, Indonesia and Japan. Presented as the first work devoted to this particular comparative inquiry, it makes a valuable contribution to Asian private international law and offers insights that will interest readers working on choice of forum agreements elsewhere.
Zamzam on Egyptian Private International Law (in Arabic): Towards Reviving the Golden Age of Egyptian Private International Law
Private international law in Egypt has often been described as being in a state of stagnation. After enormous efforts by the government since the end of the 19th century, and particularly during the beginning of the 20th century, Egypt succeeded in developing a relatively comprehensive PIL framework, covering choice of law (Arts 10–28 of the 1948 Civil Code), international jurisdiction (Arts 28–35 of the 1968 Code of Civil and Commercial Procedure), and the enforcement of foreign judgments (Arts 296–301 the 1968 Code of Civil and Commercial Procedure), alongside other rules scattered across various pieces of legislation. While these rules could be considered relatively modern and well developed, and broadly in line with the general tendencies of comparative law at the time, they have since become quite outdated and, in many respects, old-fashioned. This, however, has not prevented Egyptian law from exerting considerable influence throughout the region, with more recent codifications often reproducing or adapting Egyptian solutions.
Maintenance Duties for a Gestational Surrogate Following Non-Recognition – An Unreported Spanish Judgment
Written by Nicolás Zambrana-Tévar LLM, PhD (KIMEP University)
Facts of the case
An unreported judgment of the Family, Childhood and Capacity Section of the Tribunal de Instancia de Alicante (No. 3), dated 29 April 2026, has attracted attention for ordering a Mexican gestational surrogate to pay child maintenance to the Spanish father for whom she carried a child, despite having no custody, no exercise of parental authority, and no contact rights (here and here).
News
OUT now: Multistate Torts in European Private International Law
The new extensive Volume Multistate Torts in European Private International Law was just published by Edward Elgar Publishing. This book is the outcome of the second edition of the EAPIL Winter School in Private International Law. The contributions are based on the lectures given during the course, which took place at the Department of Law, Economics and Cultures, University of Insubria, Como, Italy, from 10 to 15 February 2025. It is edited by Silvia Marino (University of Insubria, Como), Anna Wysocka-Bar (Jagiellonian University, Kraków) and Javier Carrascosa González (University of Murcia).
The chapters discuss the current and future challenges related to the resolution of complex cases of cross-border torts and related damages. Globalisation and digitalisation are particularly crucial in these areas, where the lack of a truly common regulatory fragmentation could leave victims in a situation of helplessness. New challenges, such as distance delicts and the rise of modern social sensibilities, risk affecting the traditional goals of private international law, such as predictability and legal certainty, but especially substantive targets, as the protection of the victim and the enhancement of human rights. The Chapters of this book address these newest challenges with particular regard.
Second Seminar of the Global Network on Private International Law, Employment, and Labour Relations (GNPILE) (22 Oct 2026)
Ulla Liukkunen (University of Helsinki) has kindly shared the attached programme for the Second Seminar of the Global Network on Private International Law, Employment, and Labour Relations (GNPILE).
The event is open to all, but registration is required.
Virtual Workshop (in English) on October 6, 2026: Sandrine Brachotte and María Julia Ochoa Jiménez on “Conflicts of Worldviews and Private International Law”
On Tuesday, October 6 2026, 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).
Sandrine Brachotte (University of Antwerp) and María Julia Ochoa Jiménez (Comillas Pontifical University) will speak, in English, about the book
“Conflicts of Worldviews and Private International Law” (Hart Publishing, 2026).
This book brings together European private international law and decolonial thinking. It examines how European courts deal with conflicts between legal frameworks and postcolonised worldviews. Through three case studies—religious arbitration, Indigenous sacred land, and sexual minorities in the Global South—it shows that these conflicts are often overlooked. This results in the inadequate protection of the claims and identities of formerly colonised peoples. The book therefore proposes a more pluralist approach to jurisdiction, choice of court, and foreign law, giving greater weight to postcolonised worldviews. Prof. Ochoa Jiménez will comment on it, while focusing on private international law.
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.