Views
Review of: PP Penasthika, Unravelling Choice of Law in International Commercial Contracts: Indonesia as an Illustrative Case Study (The Hague: Eleven Publishers 2022)
Very recently, Indonesian private international law has attracted significant scholarship in the English language.[1] Dr Penasthika’s monograph (‘the monograph’)[2] is one such work that deserves attention for its compelling and comprehensive account of choice of law in international commercial contracts in Indonesia. My review attempts to capture the methodology, summarise the contents, and give a verdict on the quality of this monograph.
Mbatha v. Cutting: Implications for Litigants of Indian Origin
Guest Post by Chytanya S. Agarwal*
I. Introduction
Rising cross-border migration of people and concomitant increase in lawsuits relating to matrimonial disputes between couples brings to the forefront the issue of conflict of jurisdictional laws (219th Law Commission Report, ¶1.1-¶1.2). Mbatha v. Cutting is one such recent case that grapples with conflict of laws pertaining to divorce and division of matrimonial property when the spouses are domiciled in separate jurisdictions. In this case, the Georgian Court of Appeal dealt with competing claims from a couple who married in New York and had their matrimonial domicile in South Africa. The wife, domiciled in Georgia, USA, argued for the application of the matrimonial property regime of South Africa – their only (though temporary) common matrimonial domicile. In determining the applicable law, the Court upheld the traditional approach, which favours lex situs for real property and lex domicilii for personal property.
Views and News from the 9th Journal of Private International Law Conference 2023 in Singapore
Four years after the 8th JPIL conference in Munich, the global community of PIL scholars finally got another opportunity to exchange thoughts and ideas, this time at Singapore Management University on the kind invitation of our co-editor Adeline Chong.
The conference was kicked off by a keynote speech by Justice Philip Jeyaretnam (Singapore International Commercial Court), providing an in-depth analysis of the Court of Appeal’s decision in Anupam Mittal v Westbridge Ventures II [2023] SGCA 1 (discussed in more detail here).
The keynote was followed by a total of 23 panels and four plenary sessions, a selection of which is summarised below by our editors.
News
Book on The New Relationship between the United Kingdom and the European Union
A book on The New Relationship between the United Kingdom and the European Union was recently published. The book is edited by Dr. Emmanuel Guinchard (Liverpool John Moores University) and Prof. Carlo Panara (University of Leicester) and may be accessed here.
Overview
- Covers the whole spectrum of the new relationship between the UK and the EU
- Contains original discussion and evaluations of the impact of Brexit on UK sovereignty
- Includes both topics covered in the recent agreements and topics that have been left in a grey area
Commission Report and Staff Working Document on Brussels I recast
Today the European Commission published its eagerly awaited Commission Report on the application of the Brussels Ia Regulation (also referred to as Brussels I-bis), No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (recast). The Report is accompanied by a Staff Working Document, detailing a number of selected topics addressed in the Report. The documents rely in particular on the extensive Evaluation Study that was published in January 2023 as well as the findings of the JUDGTRUST project and the resulting book. Read more
Journal of Private International Law 20th Anniversary Conference – Programme and Registration
The 20th Anniversary Conference of the Journal of Private International Law will take place at the Faculty of Laws of University College London between 11 and 13 September 2025.A
The conference organizers, Ugljesa Grusic (UCL) and Alex Mills (UCL), and the editors of the Journal, Paul Beaumont (University of Stirling) and Jonathan Harris (King’s College London), are pleased to announce that the conference programme is now available on the conference website.
The conference will include, in the customary manner, a mixture of parallel panel sessions (on Thursday afternoon and Saturday morning) and plenary sessions (on Friday).
A limited number of non-speaker tickets and conference dinner tickets are available via the conference website, with early bird fees until 1 July 2025.