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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developed, and broadly in line with the general tendencies of comparative law at the time, they have since become quite outdated and, in many respects, old-fashioned.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
HCCH Monthly Update: September and October 2026
Membership
On 17 September 2026, Qatar deposited its instrument of acceptance of the Statute, becoming the 95th Member of the HCCH. Qatar’s membership is its first formal connection with the HCCH, bringing the total number of States and Parties connected to the HCCH to 160. More information is available here.
Conventions & Instruments
On 16 September 2026, the Republic of Moldova acceded to the 2007 Child Support Convention. With this accession, 56 States and the European Union are bound by the 2007 Child Support Convention. It will enter into force for the Republic of Moldova on 22 September 2027. More information is available here.
On 13 October 2026, Montenegro acceded to the 2000 Protection of Adults Convention. With this accession, the 2000 Protection of Adults Convention now has 17 Contracting Parties. It will enter into force for Montenegro on 1 August 2027. More information is available here.
Second Issue of Journal of Private International Law for 2026 in honour of Professor David McClean
The second issue of the Journal of Private International Law for 2026 was published yesterday. It is a special issue in honour of Professor David McClean.
It contains the following editorial, articles, and also selected bibliography of Professor David McClean:
Paul Beaumont (FRSE) , Jonathan Harris (KC (Hon.)) , Verónica Ruiz Abou-Nigm & Hans van Loon, “Editorial”
Lawrence Collins, “Evidence in civil litigation: the role of comity and principles of international law”
This contribution draws together, and where appropriate comments upon, the different contexts in which the concept of comity and the principles of public international law have played a part in cross-border issues relating to the production of evidence.
Survey for the possibility of Australia joining the Hague Judgments and Choice of Court Conventions
Sagi Peari from the University of Western Australia and his team are exploring the possibility of Australia joining the Hague Judgments and Choice of Court Conventions. They are inviting Australian legal practitioners to participate in a brief survey: Hague Project Recruitment Poster Ethics Approved. Those who also take part in a brief follow-up interview will receive a $25 token of appreciation.
Dr. Sagi Peari
Associate Professor in Private and Commercial Law
Chair, UWA Culturally and Linguistically Diverse (CALD) Working Group
Deputy Head of School (Students)- UWA Law School
Director, Master of Legal Practice Program and International Students Officer- UWA Law School
UWA Law School
Office 231 Law Link Building
M253, Perth WA 6009 Australia T: +61 8 64882604 E: sagi.peari@uwa.edu.au