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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
AAPrIL’s Feb 2026 Seminar: Pitel on ‘Reconsidering the “Proper Party” Basis for Jurisdiction’
On Thursday 12 February 2026, the Australasian Association of Private International Law (AAPrIL) is hosting its first seminar of 2026, as Professor Stephen Pitel presents free online and in-person (Qld, Australia) on the topic, ‘Reconsidering the “Proper Party” Basis for Jurisdiction’.
Abstract:
In several jurisdictions the fact that a defendant is a ‘proper party’ to a legal proceeding constitutes a sufficient basis for taking jurisdiction over that defendant. Advocates of the proper party basis rely on considerations of fairness and efficiency to support it. Do these considerations support the proper party basis, especially if it is given a wide scope? Recently Canadian courts have been reconsidering their approach to the proper party basis, as seen (somewhat opaquely) in Sinclair v Venezia Turismo, 2025 SCC 27. This presentation will explore that reconsideration and offer thoughts for changes in other jurisdictions including Australia and New Zealand.
Chair:
Mary Keyes is Professor of Law at Griffith University, and President of AAPrIL. She is a leading scholar on questions of international jurisdiction and international family law. Mary is co-author of Private International Law in Australia, and is a member of the Working Group on Jurisdiction at the Hague Conference on Private International Law.
Presenter:
Stephen Pitel Stephen G.A. Pitel is a Professor in the Faculty of Law at Western University. His research and teaching are focused on private international law, tort law, civil procedure and legal ethics. Stephen is the author of Conflict of Laws (3rd ed. 2025) and co-author of Private International Law in Common Law Canada: Cases, Text and Materials (5th ed. 2023) and Statutory Jurisdiction: An Analysis of the Court Jurisdiction and Proceedings Transfer Act (2012). His tort law scholarship includes co-authoring Fridman’s The Law of Torts in Canada (4th ed. 2020) and Cases and Materials on the Law of Torts (11th ed. 2023). In the field of legal ethics, Stephen is a contributor to Lawyers’ Ethics and Professional Regulation (4th ed. 2021). He is a former President of the Canadian Association for Legal Ethics.
Details:
Date and time: Thursday 12 February 2026, 5:00pm to 6:00pm (AEST)*
Date and time Thursday 12 February 2026, 5:00pm to 6:00pm (AEST)
in person: Griffith University, Southbank, Brisbane: Room 4.03 Building S07. The map is available here.
RSVP (essential): Please register via this link by COB Wednesday 11 February 2026, and advise whether you are attending in person or online. Please access the Teams link here. There is no cost.
* NZ. 8:00pm-9:pm; ACT, NSW, Tas and Vic. 6:00pm-7:00pm; SA, 5:30pm-6:30pm; Qld, PNG. 5:00pm-6:00pm; NT, 4:30pm-5:30pm; WA, 3:00pm-4:00pm
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.
