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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).

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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.

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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.

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Call for Papers: 2nd Riga Private International Law Conference: ‘European Private International Law: An Era of Reforms’

The following call was kindly shared with us by Aleksandrs Fillers (Riga Graduate School of Law).

This year is marked by growing discussions about revisions of the core EU private international law documents. The 2nd edition of the Riga Private International Law Conference aims to reflect on the possible changes to be encouraged and those to be discouraged. This year the conference will mostly focus on three core ‘general’ EU private international law instruments: Brussels Ibis Regulation, Rome I and Rome II Regulations.

The conference is organized by the Riga Graduate School of Law and will be held online via Zoom on 22 June 2026. Please submit abstracts of no more than 300 words to associate professor Dr. Aleksandrs Fillers (aleksandrs.fillers@rgsl.edu.lv) by 1 June 2026. We will notify you about the acceptance of papers by 5 June 2026.

Selected articles will be published in the Baltic Yearbook of International Law (indexed in Scopus).

1st Issue of Journal of Private International Law for 2026

The first issue of the Journal of Private International Law for 2026 was published today. It contains the following articles:

This article investigates the appellate review of foreign law findings, with a particular focus on the Canadian province of Quebec, where rules of private law follow the civil law tradition but remain influenced by the common law in relevant areas such as civil procedure and evidence. The first part of the article describes how the procedural treatment of foreign law in Quebec has evolved from a rigid application of English law’s fact doctrine to a more nuanced (and civilian) characterisation in the 1994 Civil Code of Quebec. The second part of the article examines appellate jurisprudence originating in Quebec and suggests that the province’s legal mixity can inform the scope of appellate review, by emphasising the importance of context over the abstract characterisation of foreign law as a whole.

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Cross-Border Protection of Cultural Property: Chinese Journal of Transnational Law, Vol. 3 Issue 1 (2026)

The Chinese Journal of Transnational Law released a landmark Special Issue titled “Cross-Border Protection of Cultural Property”. This issue brings together leading scholars from around the world to explore one of the most urgent challenges in international law today: how to better protect cultural heritages across borders in an increasingly complex global environment. Focusing on cutting-edge issues at the intersection of international law and private law concerning cultural heritage, this issue systematically examines the provenance of cultural property, mechanisms for cross-border restitution, the application of conflict of laws, and the balance of rights between states and individuals, thereby offering a multi-dimensional perspective and institutional insights to advance global cultural heritage governance. The full table of content can be found here.

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