Views
Trial Supervision System No Longer Impediment in Hong Kong’s Recognition and Enforcement of Chinese Mainland Judgments
1. Introduction
For more than 20 years after the handover, Hong Kong courts had regularly noted difficulties with the ‘trial supervision system’ 
(also known as ‘retrial procedure’ 
) in the Chinese Mainland when attempting to recognise and enforce Mainland judgments under the common law, as the trial supervision system was thought to mean that these judgments fail to meet the ‘final and conclusive’ requirement. Such thinking was criticised by scholars as problematic.[1] To address the issue, statutory regimes on the reciprocal recognition and enforcement of judgments between the Chinese Mainland and Hong Kong have been implemented. More recent studies documented changes in the judicial attitude of Hong Kong courts,[2] but there was a lack of definitive rulings to clarify the legal position. This article focuses on the most recent Hong Kong cases which confirmed that the trial supervision system in the Chinese Mainland has no automatic impact on the recognition and enforcement of Mainland judgments in Hong Kong. A party alleging that the trial supervision system has affected the finality and conclusiveness of a Mainland judgment must prove the likelihood of a retrial being ordered through factual and/or expert evidence.
REFLECTIONS ON RECENT DEVELOPMENTS IN AFRICAN PRIVATE INTERNATIONAL LAW
I. INTRODUCTION
This is the second symposium relating to private international law in Africa to be hosted on this blog, following a series that has run consistently since 2 February 2026. The first symposium, which focused on private international law in Nigeria, took place on 14 December 2020 and was jointly hosted on Afronomics and this blog. It was organised by Professor Richard Frimpong Oppong and me.
Professor Beligh Elbalti and I are deeply grateful to the scholars who agreed to participate in this symposium at short notice, including Dr Solomon Okorley, Dr Theophilus Edwin Coleman, Dr Elisa Rinaldi, Miss Anam Abdul-Majid, Mr Kitonga Mulandi, Dr Boris Awa, and Dr Abubakri Yekini.
The idea for this second symposium originated with my dear colleague, Professor Beligh Elbalti, and I am thankful to him for involving me in the leadership and organisation of this project. The symposium finds its true genesis in a larger edited volume we are currently preparing on the recognition and enforcement of foreign judgments in Africa, which examines developments across no fewer than twenty-six African jurisdictions. Read more
Protection of Forced Heirs and International Public Policy
Written by Matteo Mangone, PhD candidate in Private Law at the University of Turin
Protection of Forced Heirs and International Public Policy: A Comparative Analysis of Germany and Italy in Light of the Bundesgerichtshof Judgment of 29 June 2022
1. The German Approach
The Bundesgerichtshof (Federal Court of Justice), in its judgment of 29 June 2022, affirmed the following legal principle: the protection of mandatory heirs pertains to German public policy and, consequently, pursuant to Article 35 of EU Regulation No. 650/2012, it is possible to disregard the lex successionis designated under Article 22 of the same Regulation whenever its application does not concretely guarantee mandatory heirs a level of protection at least equivalent to that ensured by German inheritance law. Read more
News
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.
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: