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.
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
Enforcing Indian Judgments Abroad: The Hidden Costs of Révision au Fond
A recent article in the latest issue of the Asian Journal of Comparative Law revisits a feature of Indian private international law that often sits in the background of transactional and disputes practice but can decisively shape outcomes: the continued presence of révision au fond in India’s law on the recognition and enforcement of foreign judgments (REFJ).
Virtual Workshop (in English) on June 2, 2026: Thalia Kruger on „The Problem with Legal Certainty in Private International Law”
On Tuesday, June 2, 2026, 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).
Thalia Kruger (University of Antwerp) will speak, in English, about the topic
“The Problem with Legal Certainty in Private International Law”
Legal certainty is often considered foundational in private international law. It is used as justification for some of our connecting factors, and their application in time, as well as for our standards on recognition of foreign authentic instruments and judgments. However, if understood in a positivistic and precise manner, legal certainty can impede or complicate legal changes. The paper investigates where legal certainty has undesired consequences, especially in a context of righting past wrongs.
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.
VII Foro de Derecho Internacional Privado (Madrid): Call for Papers
The organizers of the VII Foro de Derecho Internacional Privado have issued a call for papers for the next edition of the Forum, which will take place at the University of Alcalá (Madrid, Spain) on 29–30 October 2026.
The Foro Europeo de Derecho Internacional Privado (FEDIPr) is a permanent seminar devoted to the study of issues arising from transnational private relationships through regular meetings focused on discussion and debate. The Forum aims to contribute to legal scholarship and scientific progress through an empirical, comparative, functional, and multidisciplinary methodology, while serving as a meeting place for specialists in Private International Law.