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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
Conference: Assimilated law – the role and future of retained EU law in the UK (Oxford, 13/14 April 2026)
The following conference announcement was kindly shared with us by Johannes Ungerer (University of Oxford).
At the University of Oxford, a conference on “Assimilated law – the role and future of retained EU law in the UK” will be held on 13 and 14 April 2026. It is jointly organised by Professor Anne Davies and Dr Johannes Ungerer; it is funded by the Institute of European and Comparative Law as part of its 30th anniversary events.
The concept, category or chimaera of assimilated law emerged in the UK after Brexit: when becoming a Non-Member State, the UK chose to retain many EU laws in its domestic legal system, and this body of law has since been labelled ‘assimilated law’. There is an urgent need to explore and understand how assimilated law operates and might develop in future in the UK. Pressing questions concern how assimilated law is to be applied and interpreted and how it and the underlying EU laws might develop and diverge over time. Courts in the UK and on the Continent already had to deal with complex matters arising with regard to assimilated law, so there is a real need to distil and disseminate academic insights. In Lipton, the UK Supreme Court dealt with some initial questions, but they only addressed a small portion of the underlying issues.
The conference will bring together legal scholars and practitioners to establish a common understanding of the practices and challenges regarding assimilated law. The conference will be structured in two parts over the course of one and a half days: first, general questions about assimilated law will be debated, so that common themes, trends, and topics can be explored. Secondly, particularly tricky issues will be addressed which pertain to assimilated law in specific areas.
Further information, including the conference programme, is available here.
JKU Linz: Tenure-Track Position for European and International Civil Procedure Law
Johannes Kepler University Linz is currently advertising a tenure-track professorship in “European and International Civil Procedure Law”.
Out Now: Checa Martínez, Instituciones de estate planning y Derecho internacional privado patrimonial (Marcial Pons 2026)
Miguel Checa Martínez (Kinship Law) has kindly shared the following summary of his latest publication on ‘Instituciones de estate planning y Derecho internacional privado patrimonial’ with us.
