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The Nigerian Court of Appeal Upholds South African Choice of Court and Choice of Law Agreement
Case Citation:
Sqimnga (Nig.) Ltd v. Systems Applications Products (Nig.) Ltd [2025] 2 NWLR 423 (Court of Appeal, Lagos Division, Nigeria)
The dispute in this case arose between two Nigerian companies, Sqimnga Nigeria Ltd (the appellant) and Systems Applications Products Nigeria Ltd (the respondent). Both parties had entered into a Master Service Agreement in Nigeria, relating specifically to software solutions. A critical provision of this agreement stipulated that the laws of South Africa would govern any disputes, and further, that South African courts would possess exclusive jurisdiction to hear any matters arising from the agreement.
When a disagreement emerged between the parties, Sqimnga Nigeria Ltd initiated legal proceedings at the Lagos State High Court. The respondent immediately contested the jurisdiction of the Nigerian court, relying on the contractual clause mandating the use of South African law and courts. Read more
Silence Is Not Submission: Chinese Court Refuses to Enforce U.S. Default Judgment Rendered in Breach of Arbitration Agreement
Written by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.
ABSTRACT
In around 2019, a Chinese court in Hebei Province refused to enforce a US default monetary judgment from a California court on the grounds that a valid arbitration agreement was in place (Sunvalley Solar Inc. v Baoding Tianwei Solarfilms Co. Ltd. (2019) Ji 01 Xie Wai Ren No. 3). This decision underscored the court’s reliance on the arbitration agreement’s validity, even though a subsequent legislative proposal to include arbitration agreements as an indirect jurisdictional filter in China’s Civil Procedure Law (2023 Amendment) was ultimately not adopted.
The Validity of the Utah Zoom Wedding in Lebanon, or the Question of Locus Celebrationis in the Digital Age
Many thanks to Karim Hammami for the tip-off
I. Introduction
Once in the 20th century, the so-called “Nevada Divorces” captured the attention of private international law scholars around the world, particularly regarding their recognition abroad. Today, a similar phenomenon is emerging with the so-called “Utah Zoom Wedding.” So, what exactly is this phenomenon? Read more
News
ZEuP – Zeitschrift für Europäisches Privatrecht 4/2025
A new issue of ZEuP – Zeitschrift für Europäisches Privatrecht is now available and includes contributions on EU private law, comparative law and legal history, legal unification, private international law, and individual European private law regimes. The full table of content can be accessed here: https://rsw.beck.de/zeitschriften/zeup. 
Decoding the Language of Law in the post-Migration Crisis Period: the Informalisation of Migration
The Jean Monnet Chair in Legal Aspects of Migration Management in the EU and in Türkiye and Bilkent University Faculty of Law cordially invite you for the next Migration Talk by Professor Paul James Cardwell (King’s College London) on “Decoding the Language of Law in the post-Migration Crisis Period: the Informalisation of Migration”.
The talk shall be held online. For the Zoom link please contact migration@bilkent.edu.tr.
Rethinking Family Law Through a European Human Rights Lens: A New Collective Volume
What does it mean to respect family life in modern Europe? With families increasingly diverse and cross-border by nature, the concept of family law is undergoing profound legal, cultural, and institutional changes. A newly published academic volume — El Derecho de Familia a la Luz del Derecho Fundamental Europeo al Respeto a la Vida Familiar — offers a rich and timely exploration of this transformation.
Edited by María Victoria Cuartero Rubio and José Manuel Velasco Retamosa, this book brings together leading voices in European family law, private international law, and human rights to examine how the fundamental right to respect for family life (Article 8 ECHR, Article 7 EU Charter) is reshaping family law across jurisdictions. Read more