Tag Archive for: enforcement

Refusal to Enforce in Egypt of a Californian (U.S.) Judgment for Lack of Reciprocity: What Has Gotten into the Egyptian Supreme Court?

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I. Introduction

Sometimes, reading court decisions leaves a strange sense of confusion, especially when the decision rendered not only contradicts a well-established line of case law, but also when the court, in the very same decision, reveals internal contradictions. Several months ago, I critically discussed on this blog a rather unusual decision of the Egyptian Supreme Court (محكمة النقض/maḥkamat an-naqḍ), in which the enforcement of a Canadian judgment was denied on the ground that reciprocity had not been established with Canada. In my comments on that decision, I expressed “significant concerns” regarding the incoherent manner in which reciprocity was addressed by the Supreme Court.

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PRC Double Interest neither Double nor Penal: Australian Courts Clear Its Name When Enforcing Chinese Judgments

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This post was kindly prepared by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.

 

[ABSTRACT]

Recent Australian case law clarifies that the “double interest” mechanism in the People’s Republic of China (hereafter ‘PRC’) monetary judgments functions as a compensatory post-judgment interest framework rather than an unenforceable penalty. This consolidates Australia’s position as a highly attractive and creditor-friendly forum for enforcing Chinese judgments. See Zhengzhou Lvdu Real Estate Group Co v Shu [2024] NSWSC 58 (6 February 2024), Fu v Pang [2025] VSC 597 (16 September 2025), and Shanghai Chenggong Industrial Co Ltd v Zhihua Chen [2025] NSWSC 1112 (27 October 2025).

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Enforcement of New York Judgments in Côte d’Ivoire: Insights from a Recent Decision of the Abidjan Commercial Court

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Many thanks to Boris Awa (Kigali Independent University ULK, Kigali, Rwanda) for the tip-off

 

I. Introduction

The recognition and enforcement of foreign judgments in Francophone African countries remains a largely underexplored subject in the literature, including in French-language scholarship. The laws of many countries have not yet been systematically analysed from a comparative perspective, and in several jurisdictions access to even the most basic information is itself a considerable challenge. This note aims to raise awareness of African private international law, in particular in Francophone Sub-Saharan African countries. The case discussed here concerns the enforcement of a New York judgment in Côte d’Ivoire. It provides an opportunity to present the Ivorian system of recognition and enforcement of foreign judgments and to examine some of the key issues addressed by the Ivorian court.

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New Rules on the Enforcement of Foreign Judgments in Saudi Arabia – Some Preliminary Observations

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Many thanks to Karim El Chazli  (Consulting and Testifying Expert on Arab Laws) for the tip-off

 

I. Introduction

The field of foreign judgments in the MENA region has witnessed additional legal developments. After Morocco, which adopted in February a new Code of Civil Procedure containing an updated regime for the enforcement of foreign judgments (see my previous on this blog), Saudi Arabia followed suit by adopting a new Execution Law (Nizam at-Tanfidh), approved by the Council of Ministers on 15 April 2026 (27–28 Shawwal 1447 H), which contains rules on the enforcement of foreign judgments. The new law replaces the existing Execution Law promulgated by Royal Decree No. M/53 of 3 July 2012 (13 Sha’baan1433 H).

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Webinar Data protection and collective actions – 19 December

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On 19th December 2025, from 10-12 CET, the European Civil Justice Centre hosts a webinar on Data protection and collective actions from a US, European and cross-border perspective.

The fast-paced development of digital technologies, and the massive, cross-border, global dimension of the processing of personal data in the Internet, have necessitated the collective enforcement of data protection rights.

This seminar delves into developments in European collective actions, mass violations of data subjects’ rights, and the use of collective actions for the protection of supra-individual and homogeneous interests in Europe and the US, and aspects of cross-border litigation.

The focus of the seminar will the research conducted by Marina Federico (Naples University) for her book Protezione dei dati personali e tutela collettiva published in 2024.

Registration for free on Eventbrite here.

Program

10.00 Xandra Kramer (Erasmus University Rotterdam/European Civil Justice Centre) – Opening and welcome

10.05 Stefaan Voet (KU Leuven/ European Civil Justice Centre) – Introduction: Developments in European collective redress

10.25 Marina Federico (University of Naples “Parthenope”) – Data protection and collective actions. Itineraries of legal comparison in Europe and the United States

11.00 Eduardo Silva de Freitas (TMC Asser Institute/Erasmus University Rotterdam) – An Apple a day won’t keep litigation away: private international law’s new path for collective data protection claims

11.15 Discussion, moderated by Stefaan Voet

AI in Arbitration: Will the EU AI Act Stand in the Way of Enforcement?

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This guest post was written by Ezzatollah Pabakhsh, Master’s Student at the University of Antwerp

The European Union has taken an unprecedented step by regulating artificial intelligence (AI) through the EU AI Act, which is the world’s first comprehensive legal framework for AI governance. According to Recital 61, Article 6(2) and Annex III, 8(a), AI tools used in legal or administrative decision-making processes—including alternative dispute resolution (ADR), when used similarly to courts and producing legal effects—are considered high risk. These tools must comply with the strict requirements outlined in Articles 8 through 27. Read more

Silence Is Not Submission: Chinese Court Refuses to Enforce U.S. Default Judgment Rendered in Breach of Arbitration Agreement

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Written by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.

 

ABSTRACT

In around 2019, a Chinese court in Hebei Province refused to enforce a US default monetary judgment from a California court on the grounds that a valid arbitration agreement was in place (Sunvalley Solar Inc. v Baoding Tianwei Solarfilms Co. Ltd. (2019) Ji 01 Xie Wai Ren No. 3). This decision underscored the court’s reliance on the arbitration agreement’s validity, even though a subsequent legislative proposal to include arbitration agreements as an indirect jurisdictional filter in China’s Civil Procedure Law (2023 Amendment) was ultimately not adopted.

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Public Review: New UN Economic Committee for Europe White Paper on Digital Product Passports & Critical Raw Materials for Batteries: Legal Conflicts and Principles for Cross-Border Cooperation

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Legal fragmentation slows down the scaling up of the Critical Raw Materials-battery value chains to meet the demands of the green transition. Digital Product Passports (DPPs) should serve as an effective digital traceability tool for business compliance, rather than creating a green barrier.

UNECE and UN/CEFACT are proud to release our White Paper for public review, offering a deep dive into:

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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

Enforcing Foreign Judgments in Egypt: A Critical Examination of Two Recent Egyptian Supreme Court Cases

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I. Introduction

The recognition and enforcement of foreign judgments in the MENA region can sometimes be challenging, as it often involves navigating complex legal frameworks (domestic law v. conventions). In addition, case law in this field has encountered difficulties in articulating the applicable guiding principles and is sometimes ambiguous, inconsistent, or even contradictory. Two recent decisions rendered by the Egyptian Supreme Court highlight this issue, alhoutgh – it must be admitted – the Court did provide some welcome clarifications. In any event, the cases reported here highlight some key issues in the recognition and enforcement of foreign judgment and offer valuable insights into the evolving landscape of this area of law in Egypt.

 

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