Views
New Rules on the Enforcement of Foreign Judgments in Saudi Arabia – Some Preliminary Observations
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).
Bahraini Supreme Court Accepts the Applicability of “Foreign” Jewish Customs in a Succession Case Involving Bahraini Jews
I. Introduction
This is certainly a genuinely interesting case from Bahrain, involving the application of “foreign” Jewish customs in a succession dispute that appears to be between Jewish Bahraini nationals. Although the case seems to lack any foreign element, its relevance to conflict of laws is nonetheless clear, since – to my knowledge – this is the first case in which the applicability of “foreign” religious customs in matters of personal status has been explicitly admitted in what appears a purely domestic case. The case also provides a broader analytical framework, raising questions about the place and applicability of non-state law in private international law (this contrasts of the recent decision of the French Supreme Court denying the applicability of Jewish law, albeit in a different context) and, more generally, about the compatibility of non-Islamic religious norms with domestic public policy frameworks in Muslim-majority legal systems.
Advocate General Emiliou’s Opinion on Case C-799/24: Res Judicata Effect Applies Despite Breach of Art 31(2) Brussels Ia
by Arvid Kerschnitzki, University of Augsburg
On 23 April 2026, Advocate General Emiliou published his opinion on Case C-799/24 – Babcock Montajes S.A. v Kanadevia Inova Steinmüller GmbH. It adds another piece to the puzzle that is the CJEU’s broad interpretation of the term ‘judgment’ in the Brussels Ia Regulation. At the same time, the case highlights the persisting problems with procedural coordination under the regulation.
News
ZEuP – Zeitschrift für Europäisches Privatrecht 2/2026
A new issue of ZEuP – Zeitschrift für Europäisches Privatrecht is now available and includes contributions on EU private law, comparative law and legal history, legal unification, private international law, and individual European private law regimes. The full table of content can be accessed here: https://rsw.beck.de/zeitschriften/zeup.
Perspectives contentieuses internationales (PCI), Volume 5
The following announcement was kindly shared with us by Fabienne Jault-Seseke
It is a special issue devoted to a dossier entitled “The Exploitation of Natural Resources in the Face of the Energy Transition,” prepared under the direction of RebeccaLegendre and Denys-Sacha Robin. It provides an opportunity to reflect on the transformations that the extractive sector as a whole is facing as a result of sustainable development policies, as well as on the multiple disputes likely to arise from the difficult reconciliation of competing considerations. Read more
Revue critique de droit international privé – Issue 2026/1
Written by Hadrien Pauchard (assistant researcher and doctoral student at Sciences Po Law School)
The first issue of the Revue Critique de droit international privé of 2026 has just come off the press and is available online. It contains three articles, nine case notes, and eight 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).
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