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Advocate General Emiliou’s Opinion on Case C-799/24: Res Judicata Effect Applies Despite Breach of Art 31(2) Brussels Ia
by Arvid Kerschnitzki, University of Augsburg
On 23 April 2026, Advocate General Emiliou published his opinion on Case C-799/24 – Babcock Montajes S.A. v Kanadevia Inova Steinmüller GmbH. It adds another piece to the puzzle that is the CJEU’s broad interpretation of the term ‘judgment’ in the Brussels Ia Regulation. At the same time, the case highlights the persisting problems with procedural coordination under the regulation.
The New Moroccan Framework on International Jurisdiction and Foreign Judgment Enforcement – A Preliminary Critical Assessment
I. Introduction
Finally out: the new Moroccan Code of Civil Procedure (Law No. 58.25), the preparation of which was previously announced on this blog, has been promulgated by Dahir (Royal Decree) No. 1.26.07 of 11 February 2026 and published in the Official Journal (Al-Jarida Ar-Rasmiyya) No. 7485 of 23 February 2026. The legislative process was fraught with difficulties, and the draft went back and forth several times before its final adoption earlier this year. The Code will enter into force six months after its publication, i.e. on 24 August 2026.
The Reception of Hilton v Guyot and Comity in the Recognition and Enforcement of Foreign Judgments in Anglophone Africa
Introduction
Hilton v Guyot, is the most influential case in the United States—and perhaps globally—on the use of comity as a basis for recognising and enforcing foreign judgments. In that case, Justice Gray of the United States Supreme Court defined comity as follows:
“No law has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived. The extent of which the law of one nation… shall be allowed to operate within the dominion of another nation, depends upon… the “comity of nations”…” Read more
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Workshop on Private International Law, Sustainability and Fashion
As part of the DFG- and AHRC-funded Fashion’s PLACE project, there will be a workshop on Private International Law, Sustainability and Fashion at the Geneva Graduate Institute on 18 June 2026 (11:00–13:00 CEST), just prior to the EAPIL conference. The event will bring together perspectives from law, sustainability and the fashion industry, with short presentations and space for discussion. If you are in Geneva and interested in the intersection of private international law, circular economy and fashion, consider coming. No sign-up necessary.
Conference: European Principles of Transnational Litigation and Their Reception Abroad (Hamburg, 8–10 Oct 2026)
On 8–10 October 2026, Julian Rapp and Wolfgang Wurmnest will be hosting a conference on European Principles of Transnational Litigation and Their Reception Abroad at the University of Hamburg.
The aim of the conference is described as follows:
As cross-border disputes grow increasingly common in today’s globalized world, reflection on key European procedural principles – and their influence beyond Europe – deserves closer examination. This conference examines how European procedural rules, particularly those shaped by the Court of Justice of the European Union, have evolved into general principles of transnational litigation. It will discuss classic jurisdictional rules (contract and tort jurisdiction, jurisdiction agreements, and lis pendens), the protection of weaker parties, and the recognition and enforcement of judgments – all reflecting the practical challenges that litigants and courts face in cross-border litigation.
EAPIL Conference in Geneva (18-20 June 2026): Last chance to register
This is the last chance to register for the third bi-annual conference of the European Association of Private International Law (EAPIL) that will take place in Geneva, Switzerland, from 18 to 20 June 2026. To register please use this link.
For more information on the conference see our earlier blog post. The program is available on the conference’s website.
EAPIL is looking forward to seeing you in Geneva!