Views
The Moroccan Supreme Court on the Authenticity of an Apostillised Certificate of Conversion to Islam
I. Introduction
As mentioned in a previous post, Morocco is not only the MENA Arab jurisdiction that has ratified the largest number of the HCCH Conventions (7 in total), but also a country where the HCCH conventions have been actively applied (see here on the application of the HCCH 1980 Child Abduction Convention, and here for a case involving the application of the HCCH 1996 Child Protection Convention). The application of the HCCH Conventions in Morocco offers valuable insights into how these HCCH instruments operate within an Islamic context, challenging the widely held assumption of the existence of an Islamic exceptionalism (though such exceptionalism does exist, but to a varying degree across the Muslim-majority countries. See e.g. Béligh Elbalti, “The Recognition and Enforcement of Foreign Filiation Judgments in Arab Countries” in Nadjma Yassari et al. (ed.), Filiation and the Protection of Parentless Children (T.M.C. Asser Press, 2019), 373-402).
An anti-suit injunction in support of an arbitration agreement in light of the EU Sanction against Russia
By Poomintr Sooksripaisarnkit, Lecturer in Maritime Law, Australian Maritime College, College of Sciences and Engineering, University of Tasmania
On 24th September 2024, Mimmie Chan J handed down the judgment of the Court of First Instance of the High Court of the Hong Kong Special Administrative Region in Bank A v Bank B [2024] HKCFI 2529. In this case, the Plaintiff (Bank A) with its base of operation in Germany was under the supervision of the German Federal Financial Supervisory Authority (BaFin). Its majority shareholder was the Defendant (Bank B) who held 99.39% shares. In turn, the Defendant was a Russian bank whose majority shareholder was the Government of the Russian Federation.
Compensation, y nada más – CJEU decides against Real Madrid in Case C-633/22
Just two days after losing to LOSC Lille in the Champions League, Real Madrid suffered another defeat against a French opponent. Among the 44 (!) judgments published this Friday by the CJEU – a flurry of decisions reminiscent of the madness that is the current Champions League format –, the Court decided a true ‘clásico’ of European private international law in Case C-633/22 Real Madrid Club de Fútbol.
News
Second Issue of Lloyd’s Maritime and Commercial Law Quarterly for 2025
The second issue of LMCLQ was recently published.
It contains the following conflict of laws works,
David Foxton, “The Applicable Law of an Arbitration Agreement: Floating or on the Rocks?”
Marcus Teo and Kah-Wai Tan, “Territoriality over Universalism”
Adrian Briggs, “Submission to a Russian Court”
Virtual Workshop (in English) on June 3, 2025: Michael Karayanni on “Voice and Exit in Private International Law: The Case of the Israeli Inter-religious Regime”
On Tuesday, June 3, 2025, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 11:00 a.m. – 12:30 p.m. (CEST). Professor Michael Karayanni (Hebrew University of Jerusalem) will speak, in English, about the topic
“Voice and Exit in Private International Law: The Case of the Israeli Inter-religious Regime”
Private international law can play a significant role in countries with inter-religious legal regimes by offering individuals an option to “exit” their personal religious law in favor of secular law in effect in a foreign country. My presentation will examine the development of the lex loci celebrationis choice of law rule within Israel’s inter-religious regime. Additionally, it will investigate whether this development has empowered individuals with an adequate “voice” to challenge community-based religious norms.
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.
RabelsZ: New issue alert
Issue 2 of RabelsZ 89 (2025) is out. All content is Open Access: CC BY 4.0 and more articles are available Online First. The full table of contents is available here.