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Mozambican Supreme Court Recognises an Indian Adoption: A Teleological Approach to the Recognition of Foreign Acts
I. Introduction
Can a foreign adoption deed be given effect in Mozambique? What procedural steps must be followed, and which requirements must be satisfied? Does the fact that the adoption takes the form of a notarial deed complicate its “recognition” in Mozambique under the applicable legal framework for the “review and confirmation of foreign judgments”? These are some of the questions addressed by the Mozambican Supreme Court in a recent decision concerning the recognition of an Indian adoption in Mozambique. The case is particularly interesting and offers valuable insights from a comparative law perspective, thus warranting closer examination.
Egyptian Supreme Court Enforces Italian Judgment: The Right Outcome despite Some Reservations
I. Introduction
The enforcement of foreign judgments depends on the legal regime applicable to the case. In common law jurisdictions, enforcement may proceed, depending on the circumstances, either by registration under a statutory regime (whether based on reciprocal arrangements or international conventions) or by an action on the foreign judgment at common law. In civil law jurisdictions, enforcement generally requires exequatur proceedings, which may be governed by domestic law or, where applicable, by an international convention. Where an international convention applies, its provisions should, in principle, govern the enforcement process, unless the convention itself provides otherwise or leaves a particular matter to be governed by domestic law.
Talaq Divorce Cases in the United States
Over the past several months, three state appellate courts in the United States have examined whether a “talaq” divorce obtained in another country is entitled to recognition as a matter of comity. In this post, I first survey the rules relating to the recognition of foreign divorce judgments in the United States. I then explain the concept of a talaq divorce. Finally, I discuss the cases.
News
Internships at the HCCH
Applications are now open for three- to six-month legal internships at the headquarters of the Permanent Bureau of the HCCH in The Hague, for the period from March to September 2027!
Interns work with our legal teams in the Family and Child Protection Law Division, the Transnational Litigation and Apostille Division, and the Commercial, Digital and Financial Law Division.
Duties may include carrying out research on particular points of private international law and/or comparative law, taking part in the preparation of HCCH meetings, and contributing to the promotion of the HCCH and its work.
Applications should be submitted by Monday, 9 November 2026 at 18.00 (CET). For more information, please visit the Internships Section of the HCCH website.
This post is published by the Permanent Bureau of the Hague Conference of Private International Law (HCCH).
Virtual Workshop (in English) on Tuesday, 3 November 2026: Brooke Marshall in our series on “Current Research in Private International Law”
On Tuesday, November 3, 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).
Brooke Marshall (University of Oxford) will speak, in English, about the topic
“Forum legis in English Law”
About the Speaker:
Brooke Marshall is an Associate Professor of the Faculty of Law, University of Oxford, and a Fellow of St Edmund Hall. Her research examines intersections both within the field of private international law and between the field and other areas of law and legal practice. Her work has a doctrinal foundation in international commercial dispute resolution and engages with normative and comparative questions raised by cross-border relationships.
About the Topic:
An initial determination by an English court as to the law that should apply to a cross-border dispute is commonplace at the jurisdictional stage, directly affecting both the assumption and exercise of jurisdiction. This project, jointly undertaken with Dr Roxana Banu, maps the substantial and increasing role played by choice of law in the jurisdictional enquiry. Focussing on the governing law gateways for service outside the jurisdiction, it provides a theoretical, historical, and doctrinal account of England’s forum legis. We explore its imperial roots, the results it produces in the case law, and whether basing the adjudicatory jurisdiction of English courts on the applicability of English law can be normatively justified in routine commercial cases.
About the Virtual Workshop Series:
The virtual workshop series “Current Research in Private International Law” is organised by Ralf Michaels and Antonia Sittig. The series features leading national and international scholars who present and discuss their work on current developments and research topics in private international law. The workshops are geared to scholars who are researching in the field of private international law, but attendance is open to all individuals having an academic interest (doctoral candidates and students are expressly invited).
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.
Vacancy: International Family Law, University of Aberdeen
The Law School of the University of Aberdeen is seeking a lecturer in International Family Law. They are offering a Teaching and Research or Teaching and Scholarship contract. The successful candidate will be contributing in undergraduate as well as specialist Honours and postgraduate teaching.
Candidates are invited to apply online by 29 October 2026.