A Follow-Up: The German Judges Association’s Response to the HCCH Draft Text of a Future Convention on Parallel Proceedings and Related Actions

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This post follows up on our earlier observations on the public consultation responses to the HCCH Draft Text of a future Convention on Parallel Proceedings and Related Actions. At the time our overview was prepared, the response of the German Judges Association was not yet available to us among the consultation materials on the HCCH website and could therefore not be included. It has since been made available, and we would like to take this opportunity to briefly add its key points to the discussion, notwithstanding that there are still coming up new responses such as the ones by Jonathan Mance (UK) – „Former Deputy President of UK Supreme Court, Co-Chair of the LC Advisory Committee”, the International Association of Consumer Law (IACL) or the Philippine Women Judges Association. We will leave it to others to comment on these.

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Private International Law Dimensions of Singapore’s New Legislation to Combat Online Harms

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Guest post by Professor YEO Tiong Min, Yong Pung How Chair Professor of Law, Yong Pung How School of Law, Singapore Management University

Much has been in the news about governmental endeavours to protect children from the ills of social media, which has partially eclipsed the equally important issue of social media being used to cause online harms to both the young and not so young alike. The Online Safety (Relief and Accountability) Act 2025 (OSRAA) came into effect in Singapore on 29 June 2026, with the objective to strengthen the protection of victims against various types of emerging online harm, including intimate image abuse, image-based child abuse, doxxing, online harassment, and online stalking. The statute established the Online Safety Commission that can make orders to hold accountable those who post harmful content (Communicators), control the hosting of the harmful content (Administrators), or host the harmful content (Platforms).

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The 1961 HCCH Apostille Convention: Why All African Countries Should Ratify It? — Insights from Judicial Practice in Africa

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I. The Apostille Convention

The HCCH has recently announced that “[o]n 9 July 2026, the Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (1961 Apostille Convention) entered into force for the People’s Democratic Republic of Algeria following the deposit of its instrument of accession on 5 November 2025.” With Algeria’s accession, the 1961 Apostille Convention now has 130 Contracting Parties, making it by far the most successful of all HCCH Conventions in terms of global participation.

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The enforcement of an advance on costs for substitute performance at the expense of a Russian debtor in German-French legal relations

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This note has been co-authored with Dr. Samuel Vuattoux-Bock, LL.M. (Kiel). It is based on a legal expert opinion for White and Case LLP, Frankfurt. A more comprehensive version – in German – is forthcoming in the Zeitschrift für Internationales Wirtschaftsrecht (IWRZ).

 

I. Introduction
International enforcement regarding the performance of actions that may be taken by others pursuant to Section 887 of the German Code of Civil Procedure (ZPO) raises complex questions within the Brussels Ibis Regulation. These issues concern the correct classification of such enforcement measures, the legal status of a third-party debtor in the context of the enforcement of monetary claims, and potential grounds for refusing enforcement that may arise with respect to international jurisdiction and any defects in service of process. Currently, French courts are seized of the question as to whether a German judgment—in which the German creditor of a Russian debtor was awarded an advance on costs pursuant to Section 887(2) ZPO—can be fully enforced in France by means of a garnishment order directed against a French third-party debtor.

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“Yes, in principle, but not quite there yet…” – Some Observations on the Public Consultation on the HCCH Draft Text of a Future Convention on Parallel Proceedings and Related Actions

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This post was written by Matthias Weller and Achim Czubaiko-Güntgen, both at the University of Bonn, Germany. Matthias is a Director of the Institute for German and International Civil Procedural Law. Achim is a PhD Student there who works on the HCCH Conventions on judicial cooperation in civil and commercial matters.

Recently, the Hague Conference on Private International Law (HCCH) published the responses to the public consultation issued in November 2025 (all available on hcch.net here). Whilst each of the 72 reports is valuable in its own right, when viewed collectively they also provide an insight in the general perception of the HCCH’s Jurisdiction Project, as it is currently standing. We would like to take this opportunity to highlight certain aspects that are widely agreed upon, as well as others that still remain subject to further debate.

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Judgment Mobility Rules in India’s Private International Law Regime: No place for a revision au fond?

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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:

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Nothing to See Here: The CJEU’s Decision in Case C-232/25 Idzinski

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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.

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Refusal to Enforce in Egypt of a Californian (U.S.) Judgment for Lack of Reciprocity: What Has Gotten into the Egyptian Supreme Court?

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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.

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PRC Double Interest neither Double nor Penal: Australian Courts Clear Its Name When Enforcing Chinese Judgments

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This post was kindly prepared by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.

 

[ABSTRACT]

Recent Australian case law clarifies that the “double interest” mechanism in the People’s Republic of China (hereafter ‘PRC’) monetary judgments functions as a compensatory post-judgment interest framework rather than an unenforceable penalty. This consolidates Australia’s position as a highly attractive and creditor-friendly forum for enforcing Chinese judgments. See Zhengzhou Lvdu Real Estate Group Co v Shu [2024] NSWSC 58 (6 February 2024), Fu v Pang [2025] VSC 597 (16 September 2025), and Shanghai Chenggong Industrial Co Ltd v Zhihua Chen [2025] NSWSC 1112 (27 October 2025).

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