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Talaq Divorce Cases in the United States
Over the past several months, three state appellate courts in the United States have examined whether a “talaq” divorce obtained in another country is entitled to recognition as a matter of comity. In this post, I first survey the rules relating to the recognition of foreign divorce judgments in the United States. I then explain the concept of a talaq divorce. Finally, I discuss the cases.
Book Review: Choice of Forum Clauses in Asia (Lemuel L Lopez)
Choice of forum clauses are an important means of managing litigation risk in international commercial contracts. Their effectiveness, however, depends on how courts understand and enforce the parties’ agreement. This well-researched book offers a substantial comparative examination of that problem across seven Asian jurisdictions: Singapore, Hong Kong, Malaysia, the Philippines, China, Indonesia and Japan. Presented as the first work devoted to this particular comparative inquiry, it makes a valuable contribution to Asian private international law and offers insights that will interest readers working on choice of forum agreements elsewhere.
Zamzam on Egyptian Private International Law (in Arabic): Towards Reviving the Golden Age of Egyptian Private International Law
Private international law in Egypt has often been described as being in a state of stagnation. After enormous efforts by the government since the end of the 19th century, and particularly during the beginning of the 20th century, Egypt succeeded in developing a relatively comprehensive PIL framework, covering choice of law (Arts 10–28 of the 1948 Civil Code), international jurisdiction (Arts 28–35 of the 1968 Code of Civil and Commercial Procedure), and the enforcement of foreign judgments (Arts 296–301 the 1968 Code of Civil and Commercial Procedure), alongside other rules scattered across various pieces of legislation. While these rules could be considered relatively modern and well developed, and broadly in line with the general tendencies of comparative law at the time, they have since become quite outdated and, in many respects, old-fashioned. This, however, has not prevented Egyptian law from exerting considerable influence throughout the region, with more recent codifications often reproducing or adapting Egyptian solutions.
News
Programme for the Online Book Launch – Choice of Law for Consumer Contracts in Theory and Practice
The following post has been kindly shared with us by Benedikt Schmitz (University of Groningen).
We are pleased to announce the programme for the upcoming virtual book launch of Choice of Law for Consumer Contracts in Theory and Practice (Edward Elgar Publishing). Building upon research conducted during Dr. Benedikt Schmitz’s doctoral studies at the University of Groningen, Schmitz updated his work to turn it into an essential reference for both practitioners and academics. The event is hosted by the WEAKER PIL research line (weakerparties.eu).
Seminar Netherlands Commercial Court – Interim Remedies
Text kindly provided by Willem Visser (Court Registrar and Senior Clerk Netherlands Commercial Court)
On 13 November 2026, the Netherlands Commercial Court is organizing a seminar on the commonalities and differences between interim remedies available under common and civil law. The speakers will be Mr Andrew Henshaw (Justice at the London Commercial Court), and professors Xandra Kramer and Gerard Meijer (Erasmus University Rotterdam).
This seminar may be joined online or in the courtroom. Registration is free of charge. For more information and registration, see Seminar: Interim Remedies – Commonalities and Differences in Common Law and Civil Law | NCC.
At this seminar also the book ‘Private International Law: a Step-by-Step Approach‘, authored by Willem Visser (Boom, 2026), will be presented.
Call for DPhil Applications
The following post has kindly been shared with us Roxana Banu (University of Oxford).
The Conflict of Laws/Private International Law academic team at the University of Oxford invites applications from students interested in pursuing a doctorate (DPhil, corresponding to a PhD) in the field. The Oxford Conflict of Laws team is one of the largest at any academic institution in the UK. It comprises four full-time faculty members (Associate Professor Roxana Banu, Professor Andrew Dickinson, Associate Professor Brooke Marshall and Dr Johannes Ungerer).