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
HCCH Monthly Update: July 2025
Conventions & Instruments
On 1 July 2025:
- The 2019 Judgments Convention entered into force for the United Kingdom. At present, 33 HCCH Members are either bound by the 2019 Judgments Convention or a Contracting Party for which the Convention has not entered into force yet (Albania, Andorra, and Montenegro). More information is available here.
- The 1996 Child Protection Convention entered into force for El Salvador. The Convention currently has 57 Contracting Parties. More information is available here.
- The 2007 Child Support Convention entered into force for Colombia. At present, 55 States and the European Union are bound by the 2007 Child Support Convention. More information is available here.
- The 2005 Choice of Court Convention entered into force for Bahrain. At present, 37 States and the European Union are bound by the 2005 Choice of Court Convention. More information is available here.
On 5 July 2025, the 1970 Evidence Convention entered into force for the Philippines. The Convention currently has 69 Contracting Parties. More information is available here.
On 24 July 2025, the Republic of Moldova acceded to the 1970 Evidence Convention. The Convention currently has 69 Contracting Parties. More information is available here.
Publications
On 22 July 2025, the Permanent Bureau announced the publication of the fifth editions of the Practical Handbooks on the Operation of the 1965 Service and 1970 Evidence Conventions. Incorporating recent developments, court decisions, and practical examples provided by experts from around the world, as well as updates from the meeting of the Special Commission held in July 2024, the fifth editions of the Handbooks are essential resources for anyone involved in the implementation and operation of the 1965 Service and 1970 Evidence Conventions. More information is available here.
Meetings & Events
On 10 July 2025, the Permanent Bureau of the HCCH and the Asian Business Law Institute co-hosted the webinar “Cross-border Commercial Dispute Resolution – Electronic Service of Documents and Remote Taking of Evidence”. More information is available here.
On 11 July 2025, the first meeting of the Working Group dedicated to the Model Forms for Chapter II of the 1970 Evidence Convention was held online, hosted by the Permanent Bureau. More information is available here.
Other Developments
On 9 July 2025, the premises of the HCCH’s Regional Office for Africa, hosted by the Kingdom of Morocco, were officially opened in Rabat. More information is available here.
On 10 July 2025, the Permanent Bureau of the HCCH announced several developments with regard to the HCCH’s International Child Abduction Database (INCADAT), including the launch of its new notification service. More information is available here.
These monthly updates are published by the Permanent Bureau of the Hague Conference on Private International Law (HCCH), providing an overview of the latest developments. More information and materials are available on the HCCH website.
Changes to the Editorial Board
We are delighted to announce that Wilson Lui will be joining our Editorial Board. Wilson holds degrees from the Universities of Oxford, Cambridge, the Chinese University of Hong Kong and the University of Hong Kong. He currently teaches at the University of Hong Kong while working towards his PhD at the University of Melbourne. His many publications include a comprehensive volume on the conflict of laws in Hong Kong, Hong Kong Private International Law (Hart 2025; together with Anselmo Reyes).
At the same time, we are sad to see Samuel Fulli-Lemaire (Université de Strasbourg), David P. Stewart (Georgetown University), and Marlene Wethmar-Lemmer (University of South Africa) retire from the blog after years of service to this project – we are all the more grateful for their contributions and wish them all the best.
Revue Critique de droit international privé – Issue 2025/2
Written by Hadrien Pauchard (assistant researcher and doctoral student at Sciences Po Law School)
The second issue of the Revue Critique de droit international privé of 2025 has just been released. It contains four articles, seven case notes and numerous book reviews. In line with the Revue Critique’s recent policy, the doctrinal part will soon be made available in English on the editor’s website (for registered users and institutions). Read more