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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
Rethinking Private International Law Through the Lens of Colonialism
Last week (7 June 2025), I had this extraordinary opportunity to give a presentation at the 138th Annual Conference of the Japanese Association of Private International Law, which took place at Seinan Gakuin Daigaku, Fukuoka – Japan. The theme of my presentation was “Private International Law and Colonialism.” In this talk, I shared some preliminary thoughts on a topic that is both extraordinarily rich and complex. The following note offers some initial reflections based on that presentation (with a few adjustments) with the aim of contributing to ongoing discussion and encouraging deeper reflection.
News
Revue critique de droit international privé – Issue 2025/4
Written by Hadrien Pauchard (assistant researcher and doctoral student at Sciences Po Law School)
The fourth and last issue of the Revue Critique de droit international privé of 2025 has just been released. It contains four articles, eight case notes, and six book reviews. In line with the Revue Critique’s policy, the doctrinal part will soon be made available in English on the editor’s website (for registered users and institutions). Read more
Conflict of laws in the South African courts: an(other) recent missed opportunity
Posted on behalf of Jason Mitchell, barrister at Maitland Chambers in London and at Group 621 in Johannesburg.
An Australian, Hannon, wants to book a Southern African safari with his partner, Murti, as a surprise birthday gift. He sees one he likes on an Australian travel website. Hannon fills in the online form.
It turns out that the website is just the agent for a South African company, Drifters Adventours. Drifters emailed Hannon the price and payment details. Attached to the email is a brochure. The brochure says, “Drifters do not accept responsibility for any loss, injury, damage, accident, fatality, delay or inconvenience experienced while on tour.” The brochure also says, “You will be required to complete and sign a full indemnity prior to your tour departure.” Read more
Part 4 of the Juridical Review for 2025
The recently published Part 4 of the Juridical Review for 2025 contains articles based on the International Perspectives on Scots Law seminar series held at the University of Stirling during 2023/2024. Some of these articles will be of interest to private international law aficionados:
‘The Pre-enactment Legislative Review Process in Scotland’ by Robert Brett Taylor and Adelyn L.M. Wilson (University of Strathclyde);
‘Taking the Transnational Nature of the UK Competition Appeal Tribunal Seriously: A Private International Law Perspective’ by Mihail Danov (University of Exeter);
‘The Evolution of Business and Human Rights Litigation against Multinational Companies’ by Mukarrum Ahmed (University of Lancaster);
‘Parties’ Intention and the Future Internationalisation of Scottish Arbitration – A Review of Scottish cases post 2010′ by Hong-Lin Yu (University of Stirling);
‘The Art of Persuasion: Embracing the Auld enemy and Beyond’ by Dr Mo Egan (University of Stirling).