Tag Archive for: Enforcement of foreign judgments

The New Moroccan Framework on International Jurisdiction and Foreign Judgment Enforcement – A Preliminary Critical Assessment

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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.

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20th Regional Private International Law Conference (6-8 November 2025, Istanbul)

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20th Regional Private International Law Conference will be held in Istanbul on 6-8 November 2025 in collaboration with Erdem&Erdem Law Office and Istanbul Arbitration Center (ISTAC). This year’s conference topics are focusing on choice of court/arbitration agreements and the enforcement of decisions rendered by chosen courts or arbitral tribunals. The conference programme can be viewed in here.

Participation is available via Zoom, through the link provided: https://us06web.zoom.us/j/84302415223?pwd=JdVlMzX7dzabawYUF6TnjKnjp8xKhf.1 (Meeting ID: 843 0241 5223 Password: 786753)

For further questions you may contact the organizers Prof. Dr. Zeynep Derya Tarman (Koç University Faculty of Law, Dean) and Prof. Dr. Ceyda Süral Efeçinar (Piri Reis University Faculty of Law, Dean) at meoba@ku.edu.tr (Dr. M. Ece Oba, Research Assistant at Koç University Faculty of Law).

Foreign Judgments and Indirect Jurisdiction in Dubai (UAE): One Step Forward, One Step Back?

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I. Introduction:

In 2024, the Dubai Supreme Court rendered a significant decision on the issue of indirect jurisdiction under UAE law. Commenting on that decision (see here), I noted that it offered “a welcome, and a much-awaited clarification regarding what can be considered one of the most controversial requirements in the UAE enforcement system” (italic in the original).

The decision commented on here touches on the same issue. Yet rather than confirming the direction suggested in the above-mentioned decision, the Court regrettably reverted to its prior, more restrictive approach. This shift raises doubts about whether a consistent jurisprudence on indirect jurisdiction is taking shape, or whether the legal framework remains fragmented and unpredictable.

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Limitation period of the enforcement of a UK judgment in Greece

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Limitation period of the enforcement of a UK judgment in Greece

A judgment issued by the Division of Maritime Disputes of the Piraeus first instance court at the end of last year [nr. 3400/2024, unreported] was confronted with an issue which seldomly appears before Greek courts.

The issue raised before the Piraeus Court of First Instance, in the context of Regulation 44/01, was the following: Is it permissible to revoke the recognition of a foreign (English) judgment (order) that  was declared  enforceable in Greece, when allegedly it is no longer enforceable in the State of origin? Read more

The Dubai Supreme Court on Indirect Jurisdiction – A Ray of Clarity after a Long Fog of Uncertainty?

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I. Introduction

It is widely acknowledged that the recognition and enforcement of foreign judgments depend, first and foremost, on whether the foreign court issuing the judgment was competent to hear the dispute (see Béligh Elbalti, “The Jurisdiction of Foreign Courts and the Enforcement of Their Judgments in Tunisia: A Need for Reconsideration”, 8 Journal of Private International Law 2 (2012) 199). This is often referred to as “indirect jurisdiction,” a term generally attributed to the renowned French scholar Bartin. (For more on the life and work of this influential figure, see Samuel Fulli-Lemaire, “Bartin, Etienne”, in J. Basedow et al. (eds.), Encyclopedia of Private International Law – Vol. I (2017) 151.)

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