Views
South Africa Grapples with the Act of State Doctrine and Choice of Law in Delict
By Jason Mitchell, barrister at Maitland Chambers in London and at Group 621 in Johannesburg.
The Supreme Court of Appeal delivered judgment today in East Asian Consortium v MTN Group. The judgment is available here.
East Asian Consortium, a Dutch company, was part of the Turkcell consortium. The consortium bid on an Iranian telecommunications licence. The consortium won the bid. East Asian Consortium alleged that it was later ousted as a shareholder of the ultimate license holder, the Irancell Telecommunications Services Company. East Asian Consortium sued, amongst others, several subsidiaries of the MTN Group, a South African telecommunications company, in South Africa. East Asian Consortium alleged that the defendants unlawfully induced the Iranian government to replace East Asian Consortium with one of the MTN subsidiaries. Read more
U.S. Court Issues Worldwide Anti-Enforcement Injunction
This post was written by Hannah Buxbaum, the John E. Schiller Chair in Legal Ethics and Professor of Law at the Indiana University Maurer School of Law in the United States.
Last month, Judge Edward Davila, a federal judge sitting in the Northern District of California in the United States, granted a motion by Google for a rare type of equitable relief: a worldwide anti-enforcement injunction. In Google v. Nao Tsargrad Media, a Russian media company obtained a judgment against Google in Russia and then began proceedings to enforce it in nine different countries. Arguing that the judgment was obtained in violation of an exclusive forum selection clause, Google petitioned the court in California for an order to block Tsargrad from enforcing it.
As Ralf Michaels and I found in a recent analysis, the anti-enforcement injunction is an unusual but important device in transnational litigation. There aren’t many U.S. cases involving these orders, and one of the leading decisions arose in the context of the wildly complicated and somewhat anomalous Chevron Ecuador litigation. As a result, there is little U.S. authority on a number of important questions, including the legal standard that applies to this form of relief and the mix of factors that courts should assess in considering its availability. Judge Davila’s decision in the Google case addresses some of these questions.
Read more
Tatlici v. Tatlici: Malta Rejects $740 Million U.S. Defamation Judgment as Turkish Case Looms
Written by Fikri Soral, Independant Lawyer, Turkey; and LL.M. student, Galatasaray University, Turkey
A Maltese court has refused to enforce a $740 million default judgment issued by the 15th Judicial Circuit Court of Florida (Palm Beach County) in a defamation suit brought by Applicant Mehmet Tatlici against his half-brother, Defendant Ugur Tatlici. [1] The Florida court’s award—issued on 8 January 2020 in a defamation suit filed by Mehmet Tatlici against his half-brother—was deemed procedurally deficient and substantively incompatible with Malta’s public policy, particularly due to its lack of reasoning and its chilling effect on free expression.[2] Read more
News
Registration open: Australasian Association of Private International Law Conference, Sydney, 16-17 April 2026
Registrations for the 2026 AAPrIL Conference, to be held on 16 and 17 Apriil 2026, are now open!
VENUE: Ashurst Lawyers
Level 8, 39 Martin Place
Sydney, New South Wales 2000
AUSTRALIA
PANELS AND SESSIONS:
- Jurisdiction
- Private International Law and Digitalisation
- Regional and International Cooperation
- Arbitration
- Applicable Law
Attendance at conference sessions can be used for CPD; you will need to check local requirements.
REGISTRATION FEES:
If you are coming for both days, please select Friday.
Non-member 2 days: $160
Non-member 1 day: $90
AAPrIL member 2 days: $120
AAPrIL member 1 day: $70
Student: Free to attend the conference only
Conference dinner: $110 for dinner and a selection of drinks
REGISTRATION INCLUDES:
Access to all conference sessions
Morning tea and coffee, morning teas and lunches
Access to purchase a conference dinner ticket at an additional cost of $110
ELI-Webinar “Enhancing Child Protection” (Int’l Filiation Law)
As already announced in another post, there will be a Webinar organized by the European Law Institute (ELI) on March 12 to present and discuss the Project Report of the ELI Project “Enhancing Child Protection: Private International Law on Filiation and the European Commission’s Proposal COM/2022/695 final”
Call for Papers: 11th Journal of Private International Law Conference (Zurich, 1–3 April 2027)
The following Call for Papers has been kindly shared with us by Christiane von Bary (University of Zurich):
Following the 20th Anniversary Conference in London (2025), we are pleased to announce that the Journal of Private International Law will be holding its 11th Conference at the University of Zurich from 1 to 3 April 2027.
We are now inviting the submission of paper proposals for the conference. Please submit an abstract if you would like to make a presentation at the conference and you are willing to produce a final paper that you will submit for publication in the Journal. Abstracts should be up to 500 words in length and should clearly state the name(s) and affiliation(s) of the author(s). Participants are also welcome to propose collective panels. If the proposal is for a panel, it should include the names and affiliations of all proposed participants.
Presentations can be on any subject matter that falls within the scope of the Journal and can be offered by people at any stage of their career, including postgraduate students and practitioners. Presentation at the conference will depend on whether your abstract is selected by the Editors of the Journal (Professor Jonathan Harris KC, King’s College, London and Professor Paul Beaumont FRSE, University of Stirling) and the conference organisers (Professors Tanja Domej and Christiane von Bary, University of Zurich). The subsequent article should be submitted to either of the editors of the Journal before the end of 2027. Publication in the Journal will be subject to the usual system of peer review.
The Conference will be held at the University of Zurich. There will be a mixture of plenary and parallel panel sessions. Speakers will not be expected to pay a conference fee but will be expected to pay for their own expenses in relation to their attendance at the conference in Zurich. Non-speakers will be expected to pay a conference fee. A conference dinner will be held on Friday (2 April 2027), at additional cost and with limited places. Details about registration, the conference dinner and options for accommodation will be made available on the conference webpage: https://t.uzh.ch/1WV.
Please send your proposal to the following e-mail address by Tuesday, 30 June 2026:
We look forward to receiving your proposals, and to welcoming you to Zurich in April 2027!