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
Second LJUBLJANA PIL Conference – express registration up to 30 June!
On 10 September 2026, the University of Ljubljana, Faculty of Law, in cooperation with the Institute for Comparative Law, will host the Second Private International Law Conference, a regional forum dedicated to current developments and emerging challenges in private international law. The conference will bring together leading academics, judges, attorneys, arbitrators, and legal practitioners from Slovenia and across Europe to discuss some of the most significant issues arising in cross-border legal practice. With the aim of engaging the international private international law community while also fostering the development and use of Slovenian legal terminology, the conference programme is divided into two parts: a morning session in Slovenian and an afternoon session in English. Abstracts of all presentations will be available in both languages.
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.