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New Proposed Rules on International Jurisdiction and Foreign Judgments in Morocco
Last Thursday, November 9, Draft No. 02.23 proposing the adoption of a new Code of Civil Procedure (al-musattara al-madaniyya) was submitted to the Moroccan House of Representatives. One of the main innovations of this draft is the introduction, for the first time in Moroccan history, of a catalogue of rules on international jurisdiction. It also amends the existing rules on the enforcement of foreign judgments.
The Jurisdiction Puzzle: Dyson, Supply Chain Liability and Forum Non Conveniens
Written by Dr Ekaterina Aristova, Leverhulme Early Career Fellow, Bonavero Institute of Human Rights, University of Oxford
On 19 October 2023, the English High Court declined to exercise jurisdiction in Limbu v Dyson Technology Ltd, a case concerning allegations of forced labour and dangerous conditions at Malaysian factories which manufactured Dyson-branded products. The lawsuit commenced by the migrant workers from Nepal and Bangladesh is an example of business and human rights litigation against British multinationals for the damage caused in their overseas operations. Individuals and local communities from foreign jurisdictions secured favourable outcomes and won jurisdictional battles in the English courts over the last years in several notable cases, including Lungowe v Vedanta, Okpabi v Shell and Begum v Maran.
Navigating Global Jurisdiction: The Indian Courts’ Approach to Online IP Infringement
Written by Akanksha Oak, Jindal Global Law School, India
Introduction
The modern commerce landscape faces a significant challenge: the widespread infringement of intellectual property (“IP”) rights due to online interactions that enable instant global access. This issue is exacerbated by cross-border activities, necessitating the application of private international law (“PIL”). However, IP protection remains territorial, guided by the principle of “lex loci protectionis.” This results in complexities when it intersects with PIL. Online IP infringement further convolutes matters due to the internet’s omnipresence and accessibility, making the establishment of jurisdiction a complicated process for legal professionals. A pivotal development in this arena occurred in 2021 when the Delhi High Court rendered a judgement in the case of HK Media Limited and Anr v. Brainlink International Inc.,[1] illuminating India’s legal framework for determining jurisdiction in cases of online IP infringement within the context of cross-border disputes.
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Virtual Workshop (in English) on June 3, 2025: Michael Karayanni on “Voice and Exit in Private International Law: The Case of the Israeli Inter-religious Regime”
On Tuesday, June 3, 2025, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 11:00 a.m. – 12:30 p.m. (CEST). Professor Michael Karayanni (Hebrew University of Jerusalem) will speak, in English, about the topic
“Voice and Exit in Private International Law: The Case of the Israeli Inter-religious Regime”
Private international law can play a significant role in countries with inter-religious legal regimes by offering individuals an option to “exit” their personal religious law in favor of secular law in effect in a foreign country. My presentation will examine the development of the lex loci celebrationis choice of law rule within Israel’s inter-religious regime. Additionally, it will investigate whether this development has empowered individuals with an adequate “voice” to challenge community-based religious norms.
The presentation will be followed by open discussion. All are welcome. More information and sign-up here.
If you want to be invited to these events in the future, please write to veranstaltungen@mpipriv.de.
RabelsZ: New issue alert
Issue 2 of RabelsZ 89 (2025) is out. All content is Open Access: CC BY 4.0 and more articles are available Online First. The full table of contents is available here.
3rd Postgraduate Law Conference at the Centre for Private International Law and Transnational Governance
The 3rd Postgraduate Law Conference of the Centre for Private International Law is now open for registration.
The theme is “New Dimensions in Private International Law” and the conference will take place online on 6 June 2025 in the morning. Topics include commercial, family and maritime law, as well as law in the digital age and sustainability and corporate responsibility.