Views
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
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.
News
SLAPP-Directive implemented in Belgium
The SLAPP (Strategic Lawsuits Against Public Participation) Directive of the EU (2024/1069 of 11 April 2024) is transposed in Belgian law by the Act of 30 May 2026. The Act was published in the Belgian Official Journal on 12 June 2026 (see the French version and the Dutch version), and will enter into force on 22 June 2026.
The main features of the Act are:
Out Now: Status and Family Relationships in European PIL
The new extensive Volume Status and Family Relationships in Private International Law was just published by Edward Elgar Publishing.
Edited by Silvia Marino (University of Insubria, Como), Anna Wysocka-Bar (Jagiellonian University, Kraków) and Javier Carrascosa González (University of Murcia), the volume, builds on the presentations delivered at the 2024 EAPIL Winter School, held in Como in February 2024. It is the second book in the European Association of Private International Law series.
African Review of International Law – Inaugural Issue & Call for Contributions
Many thanks to Boris Awa (Kigali Independent University ULK, Kigali, Rwanda) for the tip-off
The birth of a new academic journal is always good news, especially when its stated aim is “to become one of the leading scientific publications on international law” and when it is “primarily intended as a forum for African international lawyers’ reflection and research on issues of interest to Africa.” This is precisely the ambition pursued by the newly launched African Review of International Law (ARIL) / Revue africaine de droit international (RADI), published by the African Society of International Law (AfSIL).