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Greenpeace Anti-SLAPP Suit Blocked by International Antisuit Injunction
This post was written by Hannah Buxbaum, Martin Luther King Jr. Professor of Law, UC Davis School of Law. The post is cross-posted from the Transnational Litigation Blog with kind permission.
In 2019, Energy Transfer, the developer of the Dakota Access Pipeline, sued Greenpeace International, a Dutch foundation, in North Dakota state court. Last year, Greenpeace responded with an anti-SLAPP (Strategic Litigation Against Public Participation) lawsuit against Energy Transfer in Dutch court. In the latest twist in this lengthy dispute, the North Dakota Supreme Court issued an antisuit injunction last week blocking (partially) that anti-SLAPP suit.
The injunction is unusual in two respects. First, it does not actually bar Greenpeace from pursuing the Dutch action; rather, it purports to limit the issues that Greenpeace can raise in that litigation. Second, it was entered after judgment had already been reached in the North Dakota lawsuit. Read more
New Rules on the Enforcement of Foreign Judgments in Saudi Arabia – Some Preliminary Observations
Many thanks to Karim El Chazli (Consulting and Testifying Expert on Arab Laws) for the tip-off
I. Introduction
The field of foreign judgments in the MENA region has witnessed additional legal developments. After Morocco, which adopted in February a new Code of Civil Procedure containing an updated regime for the enforcement of foreign judgments (see my previous on this blog), Saudi Arabia followed suit by adopting a new Execution Law (Nizam at-Tanfidh), approved by the Council of Ministers on 15 April 2026 (27–28 Shawwal 1447 H), which contains rules on the enforcement of foreign judgments. The new law replaces the existing Execution Law promulgated by Royal Decree No. M/53 of 3 July 2012 (13 Sha’baan1433 H).
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.
News
Enforcing Indian Judgments Abroad: The Hidden Costs of Révision au Fond
A recent article in the latest issue of the Asian Journal of Comparative Law revisits a feature of Indian private international law that often sits in the background of transactional and disputes practice but can decisively shape outcomes: the continued presence of révision au fond in India’s law on the recognition and enforcement of foreign judgments (REFJ).
Virtual Workshop (in English) on June 2, 2026: Thalia Kruger on „The Problem with Legal Certainty in Private International Law”
On Tuesday, June 2, 2026, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 11:00 a.m. – 12:30 p.m. (CEST).
Thalia Kruger (University of Antwerp) will speak, in English, about the topic
“The Problem with Legal Certainty in Private International Law”
Legal certainty is often considered foundational in private international law. It is used as justification for some of our connecting factors, and their application in time, as well as for our standards on recognition of foreign authentic instruments and judgments. However, if understood in a positivistic and precise manner, legal certainty can impede or complicate legal changes. The paper investigates where legal certainty has undesired consequences, especially in a context of righting past wrongs.
The presentation will be followed by open discussion. All are welcome. More information and sign-up here.
If you want to be invited to these events in the future, please write to veranstaltungen@mpipriv.de.
VII Foro de Derecho Internacional Privado (Madrid): Call for Papers
The organizers of the VII Foro de Derecho Internacional Privado have issued a call for papers for the next edition of the Forum, which will take place at the University of Alcalá (Madrid, Spain) on 29–30 October 2026.
The Foro Europeo de Derecho Internacional Privado (FEDIPr) is a permanent seminar devoted to the study of issues arising from transnational private relationships through regular meetings focused on discussion and debate. The Forum aims to contribute to legal scholarship and scientific progress through an empirical, comparative, functional, and multidisciplinary methodology, while serving as a meeting place for specialists in Private International Law.