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The Nigerian Court of Appeal Upholds South African Choice of Court and Choice of Law Agreement
Case Citation:
Sqimnga (Nig.) Ltd v. Systems Applications Products (Nig.) Ltd [2025] 2 NWLR 423 (Court of Appeal, Lagos Division, Nigeria)
The dispute in this case arose between two Nigerian companies, Sqimnga Nigeria Ltd (the appellant) and Systems Applications Products Nigeria Ltd (the respondent). Both parties had entered into a Master Service Agreement in Nigeria, relating specifically to software solutions. A critical provision of this agreement stipulated that the laws of South Africa would govern any disputes, and further, that South African courts would possess exclusive jurisdiction to hear any matters arising from the agreement.
When a disagreement emerged between the parties, Sqimnga Nigeria Ltd initiated legal proceedings at the Lagos State High Court. The respondent immediately contested the jurisdiction of the Nigerian court, relying on the contractual clause mandating the use of South African law and courts. Read more
Silence Is Not Submission: Chinese Court Refuses to Enforce U.S. Default Judgment Rendered in Breach of Arbitration Agreement
Written by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.
ABSTRACT
In around 2019, a Chinese court in Hebei Province refused to enforce a US default monetary judgment from a California court on the grounds that a valid arbitration agreement was in place (Sunvalley Solar Inc. v Baoding Tianwei Solarfilms Co. Ltd. (2019) Ji 01 Xie Wai Ren No. 3). This decision underscored the court’s reliance on the arbitration agreement’s validity, even though a subsequent legislative proposal to include arbitration agreements as an indirect jurisdictional filter in China’s Civil Procedure Law (2023 Amendment) was ultimately not adopted.
The Validity of the Utah Zoom Wedding in Lebanon, or the Question of Locus Celebrationis in the Digital Age
Many thanks to Karim Hammami for the tip-off
I. Introduction
Once in the 20th century, the so-called “Nevada Divorces” captured the attention of private international law scholars around the world, particularly regarding their recognition abroad. Today, a similar phenomenon is emerging with the so-called “Utah Zoom Wedding.” So, what exactly is this phenomenon? Read more
News
Open Online Conference: “Cross-Border Enforcement of Child Support: Pros and Cons of the Different National Systems” on January 28th, 2026 3-5:30pm CET
The Child Support Forum in cooperation with the International Union of Judicial Officers is pleased to invite every interested stakeholders of the cross border child support recovery to an open conference on January 28th, 2026 from 3 to 5:30 pm (CET).
According to Art. 41 of Regulation (EC) No. 4/2009 and Art. 32 of the 2007 Child Support Convention, the enforcement procedure shall be governed by the law of the state of enforcement. But in practice, the prospects of successfully initiating cross-border enforcement proceedings are not always easy to assess. In order to enforce successfully, it is necessary to know the specifics of the legal system of the state of enforcement (the Requested state).
Key questions in this context are:
- What does the process of enforcement of child support looks like in different states?
- Are maintenance claims given a degree of priority?
- How do Central Authorities facilitate the ongoing enforcement of maintenance decisions?
- What are the conditions for children to be exempted from costs?
The meeting aims to review the international legal framework and provide an overview of the various national enforcement systems. Finally, the advantages and disadvantages of the different systems from a legal policy perspective shall be discussed.
The participation is free of charge but registration is required.
To register, click here.
Online Book Launch – Legal Challenges of China’s One Belt One Road Initiative: Private International Law Considerations
Following the successful release of Legal Challenges of China’s One Belt One Road Initiative: Private International Law Considerations late last year, as previously announced on this blog, co-editors Dr Poomintr Sooksripaisarnkit (University of Tasmania) and Dr Sai Ramani Gariimella (South Asian University) are pleased to invite you to an upcoming online book launch.
This virtual event will feature insights from three distinguished contributors:
- Dr Jie (Jeanne) Huang (University of Sydney)
- Dr Nobumichi Teramura (Keio University Law School)
- Professor Beligh Elbalti (The University of Osaka)
Presentations will be followed by a moderated Q & A and discussion session.
This event is open to the public; please refer to the attached flyer to scan the QR Code for Zoom access.
Supreme Court of Canada to Hear Jurisdiction Appeal
Canada’s highest court does not grant leave to appeal in many cases involving private international law. In November 2025 it granted leave to appeal from NHK Spring Co., Ltd. v Cheung, 2024 BCCA 236, in which the British Columbia Court of Appeal agreed with the court below in holding that it had jurisdiction to hear a price fixing class action. The action is interesting because it involves what could be described as a “foreign” conspiracy that had effects within Canada.
The defendants are Japanese entities and the claim alleges that they conspired to fix the price of “suspension assemblies” which are a component of hard disk drives which are in turn a component of things like computers. The claim alleges that Canadians purchased products that contained these assemblies and because of the price fixing they paid more than they otherwise would have done.