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Enforcement of New York Judgments in Côte d’Ivoire: Insights from a Recent Decision of the Abidjan Commercial Court
Many thanks to Boris Awa (Kigali Independent University ULK, Kigali, Rwanda) for the tip-off
I. Introduction
The recognition and enforcement of foreign judgments in Francophone African countries remains a largely underexplored subject in the literature, including in French-language scholarship. The laws of many countries have not yet been systematically analysed from a comparative perspective, and in several jurisdictions access to even the most basic information is itself a considerable challenge. This note aims to raise awareness of African private international law, in particular in Francophone Sub-Saharan African countries. The case discussed here concerns the enforcement of a New York judgment in Côte d’Ivoire. It provides an opportunity to present the Ivorian system of recognition and enforcement of foreign judgments and to examine some of the key issues addressed by the Ivorian court.
Investment Awards vs Sovereign Immunity: Navigating the Enforcement Maze
By Cara North, Counsel, Ashurst
The intersection of foreign State immunity and the enforcement of international arbitral awards has been a hotly contested issues in recent years. First the question was whether a State has waived immunity from court processes concerning recognition and enforcement of arbitral awards by ratifying the 1965 Convention of Settlement of Investment Disputes (ICSID Convention) – to which the answer has been yes in Australia and the England and Wales (among other jurisdictions). More recently, the question has been whether a State’s ratification of the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention) constitutes an implicit waiver of sovereign immunity, to which the High Court of Australia most recently held no.
In CCDM Holdings, LLC v The Republic of India [2026] HCA 9, the High Court of Australia unanimously held that ratification of the New York Convention does not, of itself, waive foreign State immunity under the Foreign States Immunities Act 1985 (Cth). The decision aligns Australia with the current position in the United States, Canada, and England and Wales, reinforcing an emerging common law consensus in that regard.
Courtroom Attendance as a Forum Conveniens Factor in Hamilton v Barrow
This post is written by Timon Milan Solár, Doctoral researcher, Faculty of Law, Trnava University, Slovakia.
In October 2025, the High Court of England and Wales (King’s Bench Division) handed down its judgment in Hamilton v Barrow [2025] EWHC 2593 (KB). The case concerned a failed unregulated investment scheme that collapsed in 2017, leaving investors without the possibility of recovering their investments, which ranged from £2,930 to £410,969. At first glance, the decision discusses important procedural questions, including abuse of process and champerty. However, on closer inspection, it also raises an interesting issue of English private international law that has gone overlooked. Can courtroom attendance be a factor in the forum conveniens test?
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Reminder: Deadline for submitting proposals to the JPIL Conference in Zurich (30 June 2026)
As announced previously, the next Journal of Private International Law Conference will take place in Zurich on 1–3 April 2027. With the deadline for submitting proposals for papers to present at the conference, 30 June 2026, approaching fast, the organizers would like to remind everyone of the opportunity to submit a proposal. The same deadline also applies for the travel grants offered by the University of Zurich.
More information can be found on the conference website.
Crossing Dialogues, Disciplines and Borders: How far can Private International Law go? (Call for papers)
International Symposium | 9–10 October 2026 | Faculty of Law, University of Coimbra (Portugal)

The University of Coimbra Institute for Legal Research (UCILeR), in collaboration with the Associação de Estudos Europeus de Coimbra (AEEC – Coimbra Association of European Studies), is organizing the International Symposium “Crossing Dialogues, Disciplines and Borders: How far can Private International Law go?”, to be held on 9 and 10 October 2026 at the Colégio da Trindade, Coimbra, Portugal.
Organised by Dulce Lopes and Afonso Patrão , the event brings together leading scholars, early-career researchers, and practitioners to debate the evolving role and limits of Private International Law (PIL) in novel situations that increasingly challenge its traditional scope.
Call for Papers: Annual Courts and Justice Conference 2026 (4 Dec 2026, University of Nicosia)
This Call for Papers was shared with us by Procedural Law Unit of the University of Nicosia, Cyprus.



