image_pdfimage_print

Views

No Exequatur Granted for a Panamanian Judgment in Greece Due to Public Policy Considerations [Piraeus Court of First Instance Case No. 2040/2026, Unreported]

INTRODUCTION

Following a significant hiatus, the public policy defense has re-emerged prominently in discussions surrounding the enforcement of foreign judgments, particularly in the context of a judgment issued by the Panama Maritime Court in 2024. The primary issue addressed by the Greek court was whether a foreign judgment could be recognized and enforced when the foreign court denied appellate proceedings due to the failure to post a security deposit that was both substantial and necessary for the appeal process.

Read more

Non-Qualifying Ceremonies: The Futility of Foreign Registration of Islamic Marriages under English Law

This blog note is kindly provided by Dr. Muhammad Zubair Abbasi (Lecturer, School of Law, Royal Holloway, University of London; zubair.abbasi@rhul.ac.uk). It follows the author’s previous post on this topic, which was published earlier on this blog. Read more

A few takeaways from the Conclusions & Decisions of the HCCH governing body (CGAP – 2026 meeting): parentage/surrogacy, jurisdiction project, cross-border recognition and enforcement of protection orders and a Note on the Trusts Convention

This week the Conclusions & Decisions (C&D) of the HCCH governing body, the Council on General Affairs and Policy (CGAP or Council), were published. Click the links below for the relevant language versions (English, French and Spanish).

Although a wide range of topics were discussed, I would like to focus on four items: parentage/surrogacy project, the cross-border recognition and enforcement of protection orders, the jurisdiction project and a Note on the Trusts Convention.

In my view, the C&D are significant for two reasons. First, the work related to a possible new instrument of a long-standing topic at the HCCH has been concluded (without a Convention) and secondly, a “new” topic has been inserted into the agenda of the HCCH. For more information, see below. Read more

News

1st Issue of Journal of Private International Law for 2026

The first issue of the Journal of Private International Law for 2026 was published today. It contains the following articles:

This article investigates the appellate review of foreign law findings, with a particular focus on the Canadian province of Quebec, where rules of private law follow the civil law tradition but remain influenced by the common law in relevant areas such as civil procedure and evidence. The first part of the article describes how the procedural treatment of foreign law in Quebec has evolved from a rigid application of English law’s fact doctrine to a more nuanced (and civilian) characterisation in the 1994 Civil Code of Quebec. The second part of the article examines appellate jurisprudence originating in Quebec and suggests that the province’s legal mixity can inform the scope of appellate review, by emphasising the importance of context over the abstract characterisation of foreign law as a whole.

Read more

Cross-Border Protection of Cultural Property: Chinese Journal of Transnational Law, Vol. 3 Issue 1 (2026)

The Chinese Journal of Transnational Law released a landmark Special Issue titled “Cross-Border Protection of Cultural Property”. This issue brings together leading scholars from around the world to explore one of the most urgent challenges in international law today: how to better protect cultural heritages across borders in an increasingly complex global environment. Focusing on cutting-edge issues at the intersection of international law and private law concerning cultural heritage, this issue systematically examines the provenance of cultural property, mechanisms for cross-border restitution, the application of conflict of laws, and the balance of rights between states and individuals, thereby offering a multi-dimensional perspective and institutional insights to advance global cultural heritage governance. The full table of content can be found here.

Read more

ZEuP – Zeitschrift für Europäisches Privatrecht 2/2026

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: https://rsw.beck.de/zeitschriften/zeup.

Read more

Upcoming Events