Views
The New Moroccan Framework on International Jurisdiction and Foreign Judgment Enforcement – A Preliminary Critical Assessment
I. Introduction
Finally out: the new Moroccan Code of Civil Procedure (Law No. 58.25), the preparation of which was previously announced on this blog, has been promulgated by Dahir (Royal Decree) No. 1.26.07 of 11 February 2026 and published in the Official Journal (Al-Jarida Ar-Rasmiyya) No. 7485 of 23 February 2026. The legislative process was fraught with difficulties, and the draft went back and forth several times before its final adoption earlier this year. The Code will enter into force six months after its publication, i.e. on 24 August 2026.
The Reception of Hilton v Guyot and Comity in the Recognition and Enforcement of Foreign Judgments in Anglophone Africa
Introduction
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
No Exequatur Granted for a Panamanian Judgment in Greece Due to Public Policy Considerations [Piraeus Court of First Instance Case No. 2040/2026, Unreported]
INTRODUCTION
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.
News
Proceedings of the 18th Jornadas ASADIP 2025 published
The proceedings of the 18th Jornadas ASADIP in Rio de Janeiro 2025 have been published. María Mercedes Albornoz César González, Jaime Moreno-Valle and Verónica Ruiz Abou-Nigm as editors have collected no less than 46 contributions (plus a prologue and a foreword) by authors from Latin America and elsewhere to the 800 page tome entitled “Imaginario regional – resonancia global. El derecho internacional privado interamericano y el escenario mundial”. Most are in Spanish or Portuguese, a few in English. They cover a vast array of topics, doctrinal and/or theoretical, structured along seven themes: (i) foundations, (ii) normative structure, (iii) procedure, (iv) substantive protections, (v) digitization, (vi) human rights, (vii) teaching of private international law. The volume once again demonstrates both the ambition and the high quality of private international law reasoning on the continent. It can, as can many other excellent OAS publications, be downloaded free of charge from the OAS website.
Reminder: Deadline for submitting proposals to the JPIL Conference in Zurich (30 June 2026)
As announced previously, the next Journal of Private International Law Conference will take place in Zurich on 1–3 April 2027. With the deadline for submitting proposals for papers to present at the conference, 30 June 2026, approaching fast, the organizers would like to remind everyone of the opportunity to submit a proposal. The same deadline also applies for the travel grants offered by the University of Zurich.
More information can be found on the conference website.
Crossing Dialogues, Disciplines and Borders: How far can Private International Law go? (Call for papers)
International Symposium | 9–10 October 2026 | Faculty of Law, University of Coimbra (Portugal)
The University of Coimbra Institute for Legal Research (UCILeR), in collaboration with the Associação de Estudos Europeus de Coimbra (AEEC – Coimbra Association of European Studies), is organizing the International Symposium “Crossing Dialogues, Disciplines and Borders: How far can Private International Law go?”, to be held on 9 and 10 October 2026 at the Colégio da Trindade, Coimbra, Portugal.
Organised by Dulce Lopes and Afonso Patrão , the event brings together leading scholars, early-career researchers, and practitioners to debate the evolving role and limits of Private International Law (PIL) in novel situations that increasingly challenge its traditional scope.