The case presented here, decided by the Egyptian Supreme Court (Appeal No. 11434 of 21 June 2025), provides a good illustration. Despite the Court’s well-established case law imposing certain restrictions on the use of the reciprocity requirement, this recent judgment shows that, when not applied with the necessary rigor, reciprocity can still produce significant effects that undermine the legitimate expectations of the parties.
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Béligh Elbaltihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngBéligh Elbalti2025-12-08 03:37:072025-12-08 22:56:14Reciprocity and the Enforcement of Foreign Judgments in Egypt – A Critical Assessment of a Recent Supreme Court Decision
In 2023 Su 05 Xie Wai Ren No. 8 dated March 14, 2025, the Suzhou Intermediate People’s Court of Jiangsu Province in China (Suzhou Court) recognized and enforced civil judgment HC/S194/2022 under file number HC/JUD47/2023 by the Supreme Court of Singapore (Singapore Judgment). The judgment by the Suzhou Court (Suzhou Judgment) was announced in September 2025 by the Supreme People’s Court of China (SPC) as among the fifth batch of Belt and Road Initiative (BRI) model cases. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Adeline Chonghttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngAdeline Chong2025-11-04 02:54:192025-11-04 07:18:15Court-to-court referrals and reciprocity between Chinese and Singapore courts
In a judgment (2023) Hu 01 Xie Wai Ren No. 28 dated January 8, 2025, the Shanghai International Commercial Court (Shanghai Court) recognized and enforced an order given by the General Division of the Singapore High Court after finding reciprocity between China and Singapore in the recognition and enforcement of each other’s civil and commercial judgments. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Béligh Elbaltihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngBéligh Elbalti2025-06-20 07:05:512025-06-21 07:02:20Singapore Money Order Recognized and Enforced in China
This post was written by Rose Wijeyesekera, Professor of Private and Comparative Law, Chair / Department of Private and Comparative Law – Faculty of Law, University of Colombo
Introduction
Sri Lanka (formerly known as ‘Ceylon’) is an island in the Indian Ocean, and is home to a total population of 21,763,170, consisting of Sinhalese 74.9%, Tamils 15.4%, Muslims 9.3%, and 0.5% consisting of others such as Veddhas, Burghers, and gypsies.The legal system of this island nation is a unique blend of native laws and the laws that were placed by the colonial powers from 1505 to 1947, when the country gained independence. Since then, Sri Lanka has been a democratic republic and a Unitary State governed by a constitution. The Sri Lankan legal system is primarily based on Roman-Dutch law, inherited from its colonial past under the Dutch, and English common law introduced by the British colonial rulers. Apart from these two, the legal system incorporates elements of Kandyan law (representing indigenous customs of the Sinhalese), Tesawalamai(customary laws of the Tamils of the Northern province of the country) and Muslim law. These personal laws apply in matters of personal law, such as marriage, divorce, and inheritance, depending on the community to which an individual belongs. All Muslims including the sub-categories such as Moors and Malays, are governed by Muslim Law in their personal matters, while Kandyan Sinhalese (a minority of the Sinhalese who hail from “Kandyan Provinces” / the hill country, are governed by Kandyan Law. These customary laws bear a territorial and/or a religious nature. Most of these laws are enacted, but some remain open leaving room for judicial interpretation. The court system in Sri Lanka is structured hierarchically and is designed to ensure justice through a combination of traditional and modern legal principles. The system comprises the Supreme Court at the apex, the Court of Appeal, Provincial High Courts, District Courts, Magistrate Courts, and tribunals such as Labour Tribunals, Quazi Courts, and Mediation Boards. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Béligh Elbaltihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngBéligh Elbalti2025-05-03 06:18:282025-05-04 08:53:31Legislative direction for recognition of foreign judgments in Sri Lanka: A new sign-post in the private international law landscape
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.
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Béligh Elbaltihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngBéligh Elbalti2025-02-24 13:05:272025-08-28 00:12:01Enforcing Foreign Judgments in Egypt: A Critical Examination of Two Recent Egyptian Supreme Court Cases
September 2024 Update: List of China’s Cases on Recognition of Foreign Judgments
Written by Dr. Meng Yu and Dr. Guodong Du, co-founders of China Justice Observer*
On 22 September 2024, China Justice Observer released the 2024 version of the List of China’s Cases on Recognition of Foreign Judgments.[1] To date, we have collected 109 cases involving China and 26 foreign States and regions. (Note: Foreign divorce judgments are excluded in the Case List.)
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Adeline Chonghttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngAdeline Chong2024-09-30 09:00:552024-10-01 03:21:32September 2024 Update: List of China’s Cases on Recognition of Foreign Judgments
This post is kindly provided by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.
Key Takeaways:
In June 2024, the China-ASEAN Free Trade Area Nanning International Commercial Tribunal under the Nanning Railway Transportation Intermediate Court in Guangxi ruled to recognize and enforce a Thai monetary judgment (Guangxi Nanning China Travel Service, Ltd. v. Orient Thai Airlines Co., Ltd. (2023) Gui 71 Xie Wai Ren No. 1).
Apart from being the first case of enforcing Thai monetary judgments in China, it is also the first publicly reported case confirming a reciprocal relationship based on “presumptive reciprocity”.
The Chinese court’s confirmation that “presumptive reciprocity”, as outlined in the Nanning Statement, is a form of mutual consensus between China and ASEAN countries helps to promote the circulation of judgments within the China-ASEAN region.
Egypt and its legal system occupy a unique position within the MENA region. Egyptian law and scholarship exert a significant influence on many countries in the region. Scholars, lawyers, and judges from Egypt are actively involved in teaching and practicing law in many countries in the region, particularly in the Gulf States. Consequently, it is no exaggeration to say that developments in Egyptian law are likely to have a profound impact on neighboring countries and beyond, and warrant special attention. Read more
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Béligh Elbaltihttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngBéligh Elbalti2024-03-04 03:46:402024-03-04 15:33:12Egyptian Supreme Court on the Enforcement of Foreign Judgments – Special Focus on the Service Requirement
Guest post by Professor Yeo Tiong Min, SC (honoris causa), Yong Pung How Chair Professor of Law, Yong Pung How School of Law, Singapore Management University
Merck Sharp & Dohme Corp (formerly known as Merck & Co, Inc) v Merck KGaA (formerly known as E Merck) [2021] 1 SLR 1102, [2021] SGCA 14 (“Merck”), noted previously, is a landmark case in Singapore private international law, being a decision of a full bench of the Court of Appeal setting out for the first time in Singapore law the limits of transnational issue estoppel. It was also the beginning of the deconstruction of the common law on the legal effect to be given to foreign judgments. Without ruling on the issue, the court was not convinced by the obligation theory as the rationale for the recognition of foreign in personam judgments under the common law, preferring instead to rest the law on the rationales of transnational comity and reciprocal respect among courts of independent jurisdictions. There was no occasion to depart from the traditional rules of recognition of in personam judgments in that case, and the court did not do so. However, the shift in the rationale suggested that changes could be forthcoming. While this sort of underlying movements have generally led to more expansive recognition of foreign judgments (eg, in Canada’s recognition of foreign judgments from courts with real and substantial connection to the underlying dispute), the indications in the case appeared to signal a restrictive direction, with the contemplation of a possible reciprocity requirement as a necessary condition for recognition of a foreign judgment, and a possible defence where the foreign court had made an error of Singapore domestic law.
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Adeline Chonghttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngAdeline Chong2024-01-03 08:08:082024-01-04 09:21:47Postmodernism in Singapore private international law: foreign judgments in the common law
In Yin v Wu [2023] VSCA 130, the Court of Appeal of the Supreme Court of Victoria set aside a judgment[1] which had affirmed the enforcement a Chinese judgment by an Associate Justice of the Supreme Court.[2] This was a rare instance of an Australian court considering the defence to enforcement of a foreign judgment on the basis that the judgment debtor was denied natural justice—or procedural fairness—before the foreign court.
Background
The dispute concerned a payment made by a Chinese national living in China, Di Wu, to a Chinese national living in Australia, Ke Yin. The payment was made pursuant to a foreign exchange agreement: Yin had promised to pay Wu a sum of US Dollars in exchange for Wu’s Chinese RMB.
The arrangement was made unusually through a series of Telegram and WhatsApp messages, from accounts with different numbers and aliases. (In Australia, we would say that the arrangement sounded ‘suss’.) The agreement was seemingly contrary to Chinese law, which may have contributed to the clandestine character of communications underlying the agreement; see [30].
https://conflictoflaws.net/News/2020/08/CoL_Banner-1.png00Michael Douglashttps://conflictoflaws.net/News/2020/08/CoL_Banner-1.pngMichael Douglas2023-06-12 05:59:402023-06-13 06:15:27Denial of Natural Justice as a Defence to Enforcement of a Chinese Judgment in Australia
I. Introduction