Views
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).
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.
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.
News
Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2026: Abstracts
The latest issue of the „Praxis des Internationalen Privat- und Verfahrensrechts“ (IPRax) features the following articles:
Virtual Workshop (in English) on July 7, 2026: Christopher Whytock on “Conflict of Laws Through a Human Rights Lens”
On Tuesday, July 7, 2026, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 03:30 p.m. – 05:00 p.m. (CEST).
Christopher Whytock (University of California) will speak, in English, about the topic
“Conflict of Laws Through a Human Rights Lens”
The relationship between human rights and conflict of laws (private international law) is the subject of extensive scholarship in Europe, but almost entirely neglected in the United States. Inspired by European scholarship, this project attempts to extend human rights-oriented analysis to conflict of laws in the United States. It proposes a conceptual framework for understanding the relationship between human rights and conflict of laws in the abstract, applies the framework to conflict of laws in the United States, and offers comparative insights.
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.
JLMI – Call for papers – Issue no. 2/2027
The following call for papers has kindly been shared with us by the editors of The Journal of Law, Market & Innovation (JLMI).
The Journal of Law, Market & Innovation (JLMI) welcomes submissions for its second issue of 2027.
The Call for Papers for this second issue is devoted to European Regulatory and Supervisory Bodies in the Digital Realm.
You can find the call with all the details at the following link:
A NEW CONSTELLATION OF EU STATE REGULATORY AND SUPERVISORY BODIES IN THE DIGITAL REALM
Prospective articles should be submitted in the form of full papers to submissions.jlmi@iuse.it within 1 December 2026. The publication of the issue is set for the end of July 2027.
For further information, or for consultation on a potential submission, you can contact us by email at editors.jlmi@iuse.it.
Visit our website to read the full announcement.