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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
The Personal Status Regimes in the UAE — What’s New and What Are the Implications for Private International Law? A Brief Critical Appraisal
Prologue
On 15 April 2025, the new federal UAE law on personal status (Federal Decree Law No 41 of 14 October 2024) officially entered into force ( “2024 PSL”). This law fully replaces the 2005 Federal Act on Personal Status (Federal Law No. 28 of 19 November 2005 as subsequently amended) (“2005 PSL”). The new law marks the latest step in the UAE remarkable wave of legal reforms, particularly regarding personal status matters. It follows a series of significant developments at both the federal and local levels. At the federal level, this includes the adoption of the law on Civil Personal Status (Federal Decree-Law No. 41 of 3 October 2022 on Civil Personal Status) (“2022 CPSL”) and its executive regulation. At the local level, specific legislations were adopted in the Emirate of Abu Dhabi, most notably the 2021 Law on Civil Marriages and its Effects (as subsequently amended) (“2021 ADCML”), and its Procedural Regulation. These legislative efforts collectively address what is commonly referred to as “civil family law” (for further details see previous posts on this blog here, here, here, and here). Together with the new 2024 PSL, these instruments will collectively be referred to as the “Family Law Regulations” (see Table below). Read more
Opinion of AG de la Tour in C-713/23, Trojan: A step forward in the cross-border recognition of same-sex marriages in the EU?
Dr. Carlos Santaló Goris, Postdoctoral researcher at the University of Luxembourg, offers an analysis of the Opinion of Advocate General de la Tour in CJEU, Case C-713/23, Trojan
From Coman to Trojan
On 5 June 2018, the Court of Justice of the European Union (‘CJEU’) rendered its judgment in the case C-673/16, Coman. In this landmark ruling, the CJEU decided that Member States are required to recognize same-sex marriage contracted in another Member Stated to grant a residence permit to the non-EU citizen spouse of an EU citizen under the EU Citizens’ Rights Directive. The pending case C-713/23, Trojan goes a step further than C-673/16, Coman. On this occasion, the CJEU was asked whether EU law requires a civil registry of Poland, a Member State that does not provide any form of recognition to same-sex couples, to transcribe the certificate of same-sex marriage validly contracted in another Member State. A positive answer would imply that the same-sex marriage established under German law would be able to deploy the same effects as a validly contracted marriage under Polish law. While the CJEU has not yet rendered a judgment, on 3 April 2025, Advocate General de la Tour issued his Opinion on the case. While the CJEU might decide differently from AG de la Tour, the Opinion already gives an idea of the solution that might potentially be reached by the CJEU. This post aims to analyse the case and explore its implications should the CJEU side with AG de la Tour. Read more
News
Open Position as a Research Associate at Freiburg University
The Institute for Comparative and Private International Law (Department 3) at Freiburg University (Germany) is seeking a Research Associate (m/f/d), 26%, to begin as soon as possible. Read more
ZEuP – Zeitschrift für Europäisches Privatrecht 2/2025
A new issue of ZEuP – Zeitschrift für Europäisches Privatrecht is now available and includes contributions on EU private law, comparative law and legal history, legal unification, private international law, and individual European private law regimes. The full table of content can be accessed here.
The following contributions might be of particular interest for the readers of this blog:
- Anspruchsverjährung im deutsch-spanischen Rechtsverkehr
David Cuenca Pinkert and Alexander Kronenberg on the statute of limitation in cross-border situations involving Germany and Spain: Against the background of the relevance of the application of foreign law in practice, the article analyses the institute of the statute of limitations under Spanish substantive law and also deals with similarities and differences to German law as well as selective references to conflict of laws and particularities. Due to its practical relevance, the article focuses on the treatment of the limitation period for tortious claims for damages, especially as a result of road traffic accidents. - EGMR „Klimaseniorinnen“ – Konsequenzen für private Klimaklagen?
Marc-Philippe Weller and Franka Weckner comments on the decision by the ECtHR in Klimaseniorinnen and discuss the consequences of this decision for climate litigation brought before civil courts.
ABLI-HCCH webinar: Electronic Service of Documents and Remote Taking of Evidence (10 July 2025)
Written by Catherine Shen, Senior Assistant Director, ABLI
Following successful sessions in 2021, 2022 and 2023, the Singapore-based Asian Business Law Institute (ABLI) and the Permanent Bureau of the Hague Conference on Private International Law (HCCH) return after a one-year hiatus with their fourth joint webinar, this time on electronic service of documents and remote taking of evidence.
Titled Cross-border Commercial Dispute Resolution – Electronic Service of Documents and Remote Taking of Evidence, the webinar will take place on Thursday 10 July between 5 to 6:10pm (Singapore time) or 11am to 12:10 noon (CEST), and is expected to discuss, among others, electronic transmission of requests under the Service Convention, such as the use of IT for communication among Central Authorities and other competent authorities, service by electronic means across different jurisdictions, and remote taking of evidence by video-link and electronic evidence under the Evidence Convention.
Invited speakers include Melissa Ford, Secretary of HCCH, Lucinda Orr, Partner of Enyo Law LLP, Justice Anselmo Reyes, International Judge of the Singapore International Commercial Court, and Dr Xu Guojian, Senior Partner of SGLA Law Firm.
More about the webinar and its speakers can be found in the flyer.
For more information or to register, click here. Early bird discount is available till 10 June. Queries about the webinar can be directed to Catherine of ABLI at abli_info@abli.asia.