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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
Registration Open for Bonn Conference on “International Filiation Law in the EU”, 24 / 25 September 2026
Registration is now open for the already announced conference on “International Filiation Law in the EU” dealing with questions of filiation law resulting from the EU Parenthood Proposal. More information and the registration link can be accessed at the website of the conference. Registration is esp. important for the conference dinner as spots are limited and will be provided on a first come basis.
CoL.net: New Editors
We are delighted to welcome two new editors to the Blog’s Editorial Board.
Janaína Albuquerque Azevedo Gomes is an attorney admitted in Brazil and Portugal focusing on international family law. She has experience across numerous countries and sectors, including the Brazilian government and the Hague Conference on Private International Law (HCCH).
Gustavo Ferraz de Campos Monaco is professor of private international law at the University of São Paulo, where he works at the intersection of private international law and general legal theory.
We are looking forward to their contributions.
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.