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The 1961 HCCH Apostille Convention: Why All African Countries Should Ratify It? — Insights from Judicial Practice in Africa
I. The Apostille Convention
The HCCH has recently announced that “[o]n 9 July 2026, the Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (1961 Apostille Convention) entered into force for the People’s Democratic Republic of Algeria following the deposit of its instrument of accession on 5 November 2025.” With Algeria’s accession, the 1961 Apostille Convention now has 130 Contracting Parties, making it by far the most successful of all HCCH Conventions in terms of global participation.
The enforcement of an advance on costs for substitute performance at the expense of a Russian debtor in German-French legal relations
This note has been co-authored with Dr. Samuel Vuattoux-Bock, LL.M. (Kiel). It is based on a legal expert opinion for White and Case LLP, Frankfurt. A more comprehensive version – in German – is forthcoming in the Zeitschrift für Internationales Wirtschaftsrecht (IWRZ).
I. Introduction
International enforcement regarding the performance of actions that may be taken by others pursuant to Section 887 of the German Code of Civil Procedure (ZPO) raises complex questions within the Brussels Ibis Regulation. These issues concern the correct classification of such enforcement measures, the legal status of a third-party debtor in the context of the enforcement of monetary claims, and potential grounds for refusing enforcement that may arise with respect to international jurisdiction and any defects in service of process. Currently, French courts are seized of the question as to whether a German judgment—in which the German creditor of a Russian debtor was awarded an advance on costs pursuant to Section 887(2) ZPO—can be fully enforced in France by means of a garnishment order directed against a French third-party debtor.
News
Out Now (Open Access): Heiderhoff/Queirolo (eds), Private International Law and the European Union: Developments in Contemporary Private Law, 2026
A new volume coming out of the Programme in European Private Law for Postgraduates (PEPP) has just been published as part of the Scritti di diritto privato europeo ed internazionale series.
The book, available in open access here, focuses on the emergence of new legal personality for environmental features; protection of children; alternative dispute resolution; protection of the internal market and access to justice; SLAPPs; onlice activities and private international law; jurisdiction and choice of court agreements, and tax arbitrability.
Revue critique de droit international privé – Issue 2026/2
Written by Hadrien Pauchard (assistant researcher and doctoral student at Sciences Po Law School)
The second issue of the Revue Critique de droit international privé of 2026 was just released and is accessible online. It contains two articles, eight case notes, as well as five book reviews. In line with the Revue Critique’s recent policy, the doctrinal part will soon be made available in English on the editor’s website (for registered users and institutions).
RabelsZ: Issue 2/2026
The latest issue of RabelsZ has just be released. It contains the following articles as well as an editorial with important information regarding the journal’s future governance structure and publication process. All content is Open Access: CC BY 4.0.