Hilton v Guyot, is the most influential case in the United States—and perhaps globally—on the use of comity as a basis for recognising and enforcing foreign judgments. In that case, Justice Gray of the United States Supreme Court defined comity as follows:
“No law has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived. The extent of which the law of one nation… shall be allowed to operate within the dominion of another nation, depends upon… the “comity of nations”…” Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Chukwuma Okolihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngChukwuma Okoli2026-03-25 11:19:542026-03-26 09:29:40The Reception of Hilton v Guyot and Comity in the Recognition and Enforcement of Foreign Judgments in Anglophone Africa
Following a significant hiatus, the public policy defense has re-emerged prominently in discussions surrounding the enforcement of foreign judgments, particularly in the context of a judgment issued by the Panama Maritime Court in 2024. The primary issue addressed by the Greek court was whether a foreign judgment could be recognized and enforced when the foreign court denied appellate proceedings due to the failure to post a security deposit that was both substantial and necessary for the appeal process.
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Apostolos Anthimoshttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngApostolos Anthimos2026-03-23 07:35:102026-03-23 08:01:58No Exequatur Granted for a Panamanian Judgment in Greece Due to Public Policy Considerations [Piraeus Court of First Instance Case No. 2040/2026, Unreported]
This blog note is kindly provided by Dr. Muhammad Zubair Abbasi (Lecturer, School of Law, Royal Holloway, University of London; zubair.abbasi@rhul.ac.uk). It follows the author’s previous post on this topic, which was published earlier on this blog.Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Béligh Elbaltihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngBéligh Elbalti2026-03-22 07:59:012026-03-23 08:02:22Non-Qualifying Ceremonies: The Futility of Foreign Registration of Islamic Marriages under English Law
This week the Conclusions & Decisions (C&D) of the HCCH governing body, the Council on General Affairs and Policy (CGAP or Council), were published. Click the links below for the relevant language versions (English, French and Spanish).
Although a wide range of topics were discussed, I would like to focus on four items: parentage/surrogacy project, the cross-border recognition and enforcement of protection orders, the jurisdiction project and a Note on the Trusts Convention.
In my view, the C&D are significant for two reasons. First, the work related to a possible new instrument of a long-standing topic at the HCCH has been concluded (without a Convention) and secondly, a “new” topic has been inserted into the agenda of the HCCH. For more information, see below. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Mayela Celishttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngMayela Celis2026-03-14 09:42:152026-03-14 10:58:00A few takeaways from the Conclusions & Decisions of the HCCH governing body (CGAP – 2026 meeting): parentage/surrogacy, jurisdiction project, cross-border recognition and enforcement of protection orders and a Note on the Trusts Convention
Yesterday, the Regional Court of Munich (Landgericht München I) held a highly interesting oral hearing in a dispute brought by GEMA, a German collecting society representing composers, and Suno, a generative music AI company based in Cambridge, MA. The hearing was noteworthy, first, because it gave the public an opportunity to listen to numerous international hits, from Alphaville’s Forever Young to Lou Bega’s Mambo No. 5 (and their alleged copies created by Suno) in a courtroom; and secondly, because the dispute raises some interesting questions of private international law.
After GEMA had already scored a famous victory against OpenAI in November 2025, when the same chamber of the Munich Court had held that the company had been violating the copyrights of several artists and composers by reproducing their song texts, the present proceedings differed not just in scope (focusing on the musical arrangement rather than texts) but also in its international dimension. For the first time, the claimant explicitly included the use of the protected works for training that had happened (according to both parties) exclusively in the US.
https://conflictoflaws.net/News/2026/03/GEMA-SUNO-pdf.jpg9601707Tobias Lutzihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngTobias Lutzi2026-03-10 11:38:372026-03-10 11:38:37Muscles from Munich? How German Courts Might Stop US Companies from Violating Copyright through AI Training
This case note is kindly provided by Dr. Samuel Vuattoux-Bock, LL.M. (Kiel), Freiburg University (Germany)
On February 24, 2026, the German Federal Court of Justice ruled on the Kingdom of Morocco’s claim against the German news portal “Zeit Online” (Case no. VI ZR 415/23). In 2021, the journal alleged that Morocco had spied on several lawyers, journalists, and high-ranking politicians, including French President Emmanuel Macron, using the surveillance software “Pegasus”. Morocco denied the allegations and sued the publication for damages, claiming an infringement of its general right of personality. The Federal Court of Justice of Germany, the highest court for civil and criminal matters, rejected Morocco’s claim, arguing that states do not have such a right. This decision is interesting because it lies at the intersection of private international law, national tort law, and public international law. The following article aims to present the main points of this decision in terms of both its international and substantive aspects.
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Jan von Heinhttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngJan von Hein2026-03-09 16:22:292026-03-09 20:03:48German Federal Court of Justice on the Pegasus-Software Scandal: States do not have a general right of personality
Written by Marc-Philippe Weller, Carolina Radke, and Marianna Dänner (all Heidelberg University)
On 2 March 2026, the German Federal Court of Justice (Bundesgerichtshof; “BGH”) held an oral hearing in two proceedings concerning the civil liability of companies regarding climate change. The authors of this blog post attended the hearing as members of the audience.
The German NGO Deutsche Umwelthilfe (DUH) is suing the car manufacturers BMW and Mercedes Benz, requesting a legal order obliging both companies to refrain from placing combustion engine cars on the market beyond 2030. These two proceedings join the club of (strategic) climate change lawsuits in Germany. Crucially, they are the first of their kind based on tort law to reach the German Federal Court of Justice. Accordingly, the hearing was eagerly awaited by many. The decision, which will be rendered on 23 March 2026, will undoubtedly have an impact on future climate lawsuits.
https://conflictoflaws.net/News/2026/03/1024px-BGH_-_Palais_2.jpg8151024Tobias Lutzihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngTobias Lutzi2026-03-09 12:31:492026-03-09 12:31:49Climate Litigation Before the German Federal Court of Justice – “Too Complex” for Private Law instruments?
Written by Prof Dr João Costa-Neto, Assistant Professor, Faculty of Law, University of Brasília
and Dr Pedro Pagano Payne, Academic Assistant, Faculty of Law, University of Brasília
In April 2025, the highest chamber (Corte Especial) of the Brazilian Superior Court of Justice (STJ), under Justice Maria Isabel Gallotti as rapporteur, ruled on ‘Recognition of a Foreign Judgment’ (HDE) no. 7.091/EX. The case concerned the recognition of a United States ruling changing the last name of a Brazilian national who had acquired US nationality. The Plaintiff sought recognition of (i) his US naturalisation and (ii) a ruling of the Supreme Judicial Court of Suffolk County, Massachusetts, which changed his name from ‘Ariosto Mateus de Menezes’ to ‘Matthew Windsor’. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Ralf Michaelshttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngRalf Michaels2026-03-02 07:10:192026-03-02 08:33:11Brazilian Ruling Recognises US Name Change
This post is posted on behalf of Arnav Sharma, Jindal Global Law School, Sonipat, India
Introduction
On 25th July 2025, a single judge bench of the Delhi High Court delivered a judgment in Engineering Projects (India) Limited v. MSA Global LLC (Oman) in CS (OS) 243 of 2025[1] that has stirred considerable discourse in international arbitration circles. The fundamental question at issue in the instant case was whether an Indian Court can grant an anti-arbitration injunction to stay proceedings in a foreign-seated arbitration on grounds of the proceedings turning oppressive and vexatious due to procedural impropriety, notwithstanding internationally well-settled principles of minimal judicial intervention, party autonomy, and lex arbitri that govern international commercial arbitration? The Delhi High Court answered in the affirmative, holding that Indian civil courts possess inherent power under Section 9 read with Section 151 of the Code of Civil Procedure, 1908 (“CPC”) to intervene under exceptional circumstances where the arbitral process itself becomes a vehicle of abuse.
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Saloni Khanderiahttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngSaloni Khanderia2026-02-28 06:55:582026-02-28 09:27:25Anti-Arbitration Injunction in Foreign-Seated Arbitrations: The Delhi High Court’s Controversial Intervention in Engineering Projects (India) Limited v. MSA Global LLC (Oman)
The Indonesian Personal Data Protection Law, Law Number 27 of 2022 (Indonesian PDP Law), came into effect on 17 October 2022. Before its enactment, data protection rules in Indonesia were fragmented across different sector-specific laws and regulations. The Indonesian PDP Law aims to unify these laws and regulations, providing greater clarity and ensuring consistent personal data protection across all sectors in the country. The Indonesian PDP Law sets out normative provisions on personal data protection; however, detailed, practical rules have yet to be specified in the implementing regulations. As of now, the drafting of these implementing regulations is still underway. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Adeline Chonghttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngAdeline Chong2026-02-25 03:17:532026-02-27 09:17:16Cross-Border Personal Data Transfers: The Remaining Issues Following the Indonesian Constitutional Court Decision
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