Views
The 1961 HCCH Apostille Convention: Why All African Countries Should Ratify It? — Insights from Judicial Practice in Africa
I. The Apostille Convention
The HCCH has recently announced that “[o]n 9 July 2026, the Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (1961 Apostille Convention) entered into force for the People’s Democratic Republic of Algeria following the deposit of its instrument of accession on 5 November 2025.” With Algeria’s accession, the 1961 Apostille Convention now has 130 Contracting Parties, making it by far the most successful of all HCCH Conventions in terms of global participation.
The enforcement of an advance on costs for substitute performance at the expense of a Russian debtor in German-French legal relations
This note has been co-authored with Dr. Samuel Vuattoux-Bock, LL.M. (Kiel). It is based on a legal expert opinion for White and Case LLP, Frankfurt. A more comprehensive version – in German – is forthcoming in the Zeitschrift für Internationales Wirtschaftsrecht (IWRZ).
I. Introduction
International enforcement regarding the performance of actions that may be taken by others pursuant to Section 887 of the German Code of Civil Procedure (ZPO) raises complex questions within the Brussels Ibis Regulation. These issues concern the correct classification of such enforcement measures, the legal status of a third-party debtor in the context of the enforcement of monetary claims, and potential grounds for refusing enforcement that may arise with respect to international jurisdiction and any defects in service of process. Currently, French courts are seized of the question as to whether a German judgment—in which the German creditor of a Russian debtor was awarded an advance on costs pursuant to Section 887(2) ZPO—can be fully enforced in France by means of a garnishment order directed against a French third-party debtor.
News
European Group on the Digitalisation of Justice: Call for Expression of Interest
Susanne Gössl (Bonn), Frederick Rieländer (Bremen), and Benedikt Schmitz (Groningen) are happy to announce the creation of the European Group on the Digitalisation of Justice (EGDJ), a Chapter-based collaborative research network dedicated to analysing, evaluating, and shaping the ongoing digital transformation of judicial systems across Europe. It focuses on end-users, the judiciary as well as public administrations, and broader systematic changes.
Conference: Conflict of Laws in International Arbitration (Vienna, 30 Nov & 1 Dec)
This announcement has kindly been provided by Matthias Lehmann and Lukas Petschning (University of Vienna).
On 30 November and 1 December 2026, the University of Vienna (Section for Comparative, Uniform and Private International Law) will host a conference entitled „Conflict of Laws in International Arbitration“.
Call for Papers: Third Conflict of Laws Annual Workshop (CLAW3)
This announcement has kindly been shared with us by Roger Michalski (University of Oklahoma).
We are excited to announce that the Third Conflict of Laws Annual Workshop (CLAW3) will be hosted by the University of Pennsylvania Carey Law School on Friday, November 13, 2026 with a welcome dinner the night before. The CLAW aims to provide a forum to discuss new work in conflict of laws. The CLAW welcomes work on all aspects of conflict of laws, including civil, criminal, domestic and transnational conflict of laws. We welcome all those writing and working in the field of conflict of laws to attend.