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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.

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Non-Qualifying Ceremonies: The Futility of Foreign Registration of Islamic Marriages under English Law

This blog note is kindly provided by Dr. Muhammad Zubair Abbasi (Lecturer, School of Law, Royal Holloway, University of London; zubair.abbasi@rhul.ac.uk). It follows the author’s previous post on this topic, which was published earlier on this blog. Read more

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.

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