Views
Beyond Domicile: The BHP Litigation and the Functional Interconnection of Public and Private International Law
from Marcel Vitor de Magalhães e Guerra
On 14 November 2025, the English High Court handed down its Stage 1 judgment in Município de Mariana and others v. BHP Group Plc and BHP Group Limited [2025] EWHC 3001 (TCC), finding the defendants liable — under Brazilian law — for the 2015 collapse of the Fundão tailings dam: over 600,000 claimants, an estimated £36 billion, the largest group litigation in English legal history. This post argues that Mariana exposes a functional interconnection between public and private international law at the stage of determining jurisdiction itself: although doctrinally distinct, the court’s application of a private international law rule required engaging questions of corporate organisation, adjudicatory legitimacy, and transnational responsibility that traditionally belong to public international law. Read more
Conflicts of jurisdiction in Senegal: lesson from the Senegalese Supreme Court on Lis Pendens and the Exequatur of foreign judgments
This post was kindly prepared by Véronique Carole Ngono, Professor of Private Law (agrégée), University of Douala, Cameroon.
I. Introduction
The recognition and enforcement of foreign judgments in French-speaking sub-Saharan Africa has not been the subject of many studies. Although a few such studies do exist, this is in contrast to the field of conflict of laws and personal status law in particular. Consequently, the two rulings issued by the Supreme Court of Senegal on August 12, 2020, in connected disputes went practically unnoticed, even though they offer valuable insights into determining the jurisdiction of Senegalese courts in international disputes and the enforcement of foreign judgments.
The purpose of this note is therefore to shed light on the law and practice of conflict jurisdictions in Senegal.
Adoption in the proposal for a European Parenthood Regulation
This post was written by Aukje Mens, Jurist at INEA, the Dutch expertise centre on intercountry adoption. She wrote in her own name.
Recently, an article I wrote about adoption in the proposal for a European Parenthood Regulation was published in the Dutch Journal of Family and Youth Law (Tijdschrift voor Familie- en Jeugdrecht, 2026/3). This article examines the uncertainties and gaps in the regulation of adoption and argues for an autonomous European Adoption Regulation to adequately govern international adoptions. Below is a summary in English of the article.
News
Private International Law Festival 24-25 September 2026: Registration Open
Breakdown of the Rules-Based International Order
– What Role for Private International Law?
Following the first Private International Law Festival in 2022 (conference report), on 24-25 September 2026, the University of Edinburgh Law School and the Max Planck Institute for Comparative and International Private Law, generously supported by the Lindemann Foundation, will cohost the second Private International Law Festival at Edinburgh University’s splendid Playfair Library in Edinburgh. Two days of conflict of laws, plus a Ceilidh!
The program is here, a flyer is here. As to the Ceilidh, no prior expertise is expected, but you can take a look here.
Registration is open until August 28, please register here.
ZEuP – Zeitschrift für Europäisches Privatrecht 3/2026
A new issue of ZEuP – Zeitschrift für Europäisches Privatrecht is now available and includes contributions on EU private law, comparative law and legal history, legal unification, private international law, and individual European private law regimes. The full table of content can be accessed here: https://rsw.beck.de/zeitschriften/zeup. 