Views
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
Muscles from Munich? How German Courts Might Stop US Companies from Violating Copyright through AI Training
Yesterday, the Regional Court of Munich (Landgericht München I) held a highly interesting oral hearing in a dispute brought by GEMA, a German collecting society representing composers, and Suno, a generative music AI company based in Cambridge, MA. The hearing was noteworthy, first, because it gave the public an opportunity to listen to numerous international hits, from Alphaville’s Forever Young to Lou Bega’s Mambo No. 5 (and their alleged copies created by Suno) in a courtroom; and secondly, because the dispute raises some interesting questions of private international law.
After GEMA had already scored a famous victory against OpenAI in November 2025, when the same chamber of the Munich Court had held that the company had been violating the copyrights of several artists and composers by reproducing their song texts, the present proceedings differed not just in scope (focusing on the musical arrangement rather than texts) but also in its international dimension. For the first time, the claimant explicitly included the use of the protected works for training that had happened (according to both parties) exclusively in the US.
News
European Civil Procedure Seminar, Leuven, 25 and 26 June 2026
The European Civil Justice Centre is pleased to announce a European Civil Procedure Seminar, which will take place on 25 and 26 June 2026 at the Faculty of Law and Criminology of KU Leuven.
The seminar is organised on the occasion of the publication of European Civil Procedure, edited by Xandra Kramer, Stefaan Voet and Adriani Dori, and published by de Gruyter in 2026. The book offers a comprehensive overview of the main developments shaping civil justice, including EU instruments on jurisdiction, recognition and enforcement, service of documents, taking of evidence, and collective redress.
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.