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Bahraini Supreme Court Accepts the Applicability of “Foreign” Jewish Customs in a Succession Case Involving Bahraini Jews

I. Introduction

This is certainly a genuinely interesting case from Bahrain, involving the application of “foreign” Jewish customs in a succession dispute that appears to be between Jewish Bahraini nationals. Although the case seems to lack any foreign element, its relevance to conflict of laws is nonetheless clear, since – to my knowledge – this is the first case in which the applicability of “foreign” religious customs in matters of personal status has been explicitly admitted in what appears a purely domestic case. The case also provides a broader analytical framework, raising questions about the place and applicability of non-state law in private international law (this contrasts of the recent decision of the French Supreme Court denying the applicability of Jewish law, albeit in a different context) and, more generally, about the compatibility of non-Islamic religious norms with domestic public policy frameworks in Muslim-majority legal systems.

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Advocate General Emiliou’s Opinion on Case C-799/24: Res Judicata Effect Applies Despite Breach of Art 31(2) Brussels Ia

by Arvid Kerschnitzki, University of Augsburg

On 23 April 2026, Advocate General Emiliou published his opinion on Case C-799/24 – Babcock Montajes S.A. v Kanadevia Inova Steinmüller GmbH. It adds another piece to the puzzle that is the CJEU’s broad interpretation of the term ‘judgment’ in the Brussels Ia Regulation. At the same time, the case highlights the persisting problems with procedural coordination under the regulation.

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The New Moroccan Framework on International Jurisdiction and Foreign Judgment Enforcement – A Preliminary Critical Assessment

I. Introduction

Finally out: the new Moroccan Code of Civil Procedure (Law No. 58.25), the preparation of which was previously announced on this blog, has been promulgated by Dahir (Royal Decree) No. 1.26.07 of 11 February 2026 and published in the Official Journal (Al-Jarida Ar-Rasmiyya) No. 7485 of 23 February 2026. The legislative process was fraught with difficulties, and the draft went back and forth several times before its final adoption earlier this year. The Code will enter into force six months after its publication, i.e. on 24 August 2026.

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News

EAPIL Conference in Geneva (18-20 June 2026): Last chance to register

This is the last chance to register for the third bi-annual conference of the European Association of Private International Law (EAPIL) that will take place in Geneva, Switzerland, from 18 to 20 June 2026. To register please use this link.

For more information on the conference see our earlier blog post.  The program is available on the conference’s website.

EAPIL is looking forward to seeing you in Geneva!

11th Journal of Private International Law Conference 2027: Travel grants for speakers from low- and lower-middle-income economies

Reposted from JPIL Conference 2027 | Rechtswissenschaftliche Fakultät | UZH

The 11th Journal of Private International Law Conference will be held in Zurich, Switzerland. Please save the date: 1–3 April 2027.

The conference organizers Tanja Domej (University of Zurich) and Christiane von Bary (University of Zurich), as well as the editors of the Journal, Paul Beaumont (University of Stirling) and Jonathan Harris (King’s College London), are looking forward to welcoming you in Switzerland!

The call for papers is available here (PDF, 137 KB).

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German Society of International Law: Short Conference on “Law without Borders? Extraterritorial Regulation and Unilateral Action” (Munich, 11/12 June 2026)

The German Society of International Law (GSIL) will be hosting a ‘short conference’ dedicated to “Law without Borders? Extraterritorial Regulation and Unilateral Action” in Munich on 11 and 12 June 2026. While its academic events are usually limited to members of the Society, this particular event has been opened up for other academics working on questions of international law, including doctoral candidates. Participation is free of charge.

The programme can be found here; registration is possible here.

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