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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.
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.
News
Webinar on the New ICC Arbitration Rules
On 8 July, King&Spalding will be hosting a webinar on the new ICC Arbitration Rules, which entered into force last month.
The webinar will feature contributions from multiple members of the firms arbitration practice as well as a Q&A.
More information and an option to register can be found here.
Conference on Wills Substitutes (Lausanne, 8 September 2026)
On 8 September 2026 Andrea Bonomi and the Centre for Comparative, European and International Law of the University of Lausanne are organizing a conference titled „Wills substitutes” in comparative and private international law.
Speakers include: Michael W. Galligan (New York), Edward Reed (London) and Jeffrey Talpis (Montreal), Charlotte Wendland (Munich), Sophie Lambert (Aix-Marseille), François Derème (Mons), Angelo Chianale (Turin), Francesco Schurr (Liechtenstein) and Julien Perrin (Lausanne).
Discussions will be held partly in French and partly in English.
The full programme is available here.
Participants may join onsite in Lausanne or online. The registration form can be found here. University scholars may contact the organizer for discounted rates (at andrea.bonomi@unil.ch).
Online Book Launch – Choice of Law for Consumer Contracts in Theory and Practice
The following announcement has kindly been shared with us by Dr. Benedikt Schmitz.
Save the Date: 4 November 2026
Online Book Launch – Choice of Law or Consumer Contracts in Theory and Practice
We are pleased to announce an upcoming virtual book launch for Dr. Benedikt Schmitz’s new monograph, Choice of Law for Consumer Contracts in Theory and Practice (Edward Elgar Publishing). The event is hosted by the WEAKER PIL research line (weakerparties.eu).
- Date & Time: 4 November 2026, 15:00 – 17:00 CET, online
- Topic: The event will examine cross-border consumer protection and the complex conflict-of-laws frameworks regulating the global surge in online shopping. Panelists will discuss many aspects of Article 6 Rome I Regulation, including the historical dimensions of consumer protection in applicable law, the targeting test and consumer definition, the restriction to party autonomy, its ex officio application, and the US American approach to cross-border consumer contracts.