Views
Judgment Mobility Rules in India’s Private International Law Regime: No place for a revision au fond?
This post was kindly prepared by Sai Ramani Garimella, Associate Professor, Faculty of Legal Studies, South Asian University.
A judgment-creditor is often concerned about the enforcement of foreign court orders, and that concern is not completely misplaced in India. The Supreme Court’s decision in Messer Griesheim v Goyal MG Gases is a useful illustration of the law governing the enforcement of foreign court orders and of the discussion of their finality and binding nature. Twenty-three years after the underlying loan transaction, and after much litigation, the Court has finally closed the chapter, refusing to enforce a 2006 English court’s summary judgment for roughly USD 5.8 million. Along the way, it has also clarified two recurring questions that often come up whenever a foreign money decree is sought to be executed in India:
Nothing to See Here: The CJEU’s Decision in Case C-232/25 Idzinski
Earlier today, the Court of Justice rendered its decision in Case C-232/25 Idzinski, essentially confirming its previous case law, combined with a restrictive reading of its infamous decision in Joint Cases C-509/09 and C-161/10 eDate.
The facts of the case (which was given the entirely fictitious name Idzinski) are eerily similar to those of the Court’s 2021 decision in Case C-800/19 Mittelbayrischer Verlag. Just like in that earlier case, they involved a claim by Polish claimants against a German media outlet regarding the correction of, and damages for, the publication of content that allegedly violated their personality rights, including their national dignity. Only two elements of the facts were different: first, the content complained of was broadcasted on television, in addition to being published online; second, the claimants were (1) a private person who was part of a Polish military unit during World War II, which the German broadcaster had allegedly portrayed as ‘anti-Semitic and nationalistic and as having collaborated with the Nazis in the Holocaust’, and (2) an association bringing together members of that unit.
After two decisions against the defendants (to varying degrees), the Polish Supreme Court had submitted two questions relating to the international jurisdiction of the Polish courts.
Refusal to Enforce in Egypt of a Californian (U.S.) Judgment for Lack of Reciprocity: What Has Gotten into the Egyptian Supreme Court?
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.
News
Second LJUBLJANA PIL Conference – express registration up to 30 June!
On 10 September 2026, the University of Ljubljana, Faculty of Law, in cooperation with the Institute for Comparative Law, will host the Second Private International Law Conference, a regional forum dedicated to current developments and emerging challenges in private international law. The conference will bring together leading academics, judges, attorneys, arbitrators, and legal practitioners from Slovenia and across Europe to discuss some of the most significant issues arising in cross-border legal practice. With the aim of engaging the international private international law community while also fostering the development and use of Slovenian legal terminology, the conference programme is divided into two parts: a morning session in Slovenian and an afternoon session in English. Abstracts of all presentations will be available in both languages.
International colleagues are warmly invited to join the afternoon programme, which features the following speakers:
Stefania Bariatti of the University of Milan,
Hans van Loon, former Secretary General of the Hague Conference of Private International Law,
Gilles Cuniberti of the University of Luxemburg and President of EAPIL,
Ivana Kunda of the University of Rijeka,
Marko Bošnjak, judge at the Court of Justice of the CJEU,
Ana Kerševan, State Attorney General of Slovenia, and
Judita Dolžan of the Permanent Representation of the Republic of Slovenia to the European Union.
The morning session (in Slovenian) with Vesna Rijavec, Aleš Galič, Jerca Kramberger Škerl, Andrej Bebler, Filip Dougan, Urban Vrtačnik, and Borut Leskovec, will focus on practical and doctrinal issues, such as the cross-border effects of enforceable notarial deeds, applicable laws in international commercial arbitration, strategic lawsuits against public participation (SLAPP), reinsurance contracts, the European Payment Order, cross-border property relations of couples, and international family law disputes.
More information is available in the Programme.
Registration: IPP-PF : Inštitut za primerjalno pravo – Registration form PIL conference
Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2026: Abstracts
The latest issue of the „Praxis des Internationalen Privat- und Verfahrensrechts“ (IPRax) features the following articles:
Virtual Workshop (in English) on July 7, 2026: Christopher Whytock on “Conflict of Laws Through a Human Rights Lens”
On Tuesday, July 7, 2026, the Hamburg Max Planck Institute will host its monthly virtual workshop Current Research in Private International Law at 03:30 p.m. – 05:00 p.m. (CEST).
Christopher Whytock (University of California) will speak, in English, about the topic
“Conflict of Laws Through a Human Rights Lens”
The relationship between human rights and conflict of laws (private international law) is the subject of extensive scholarship in Europe, but almost entirely neglected in the United States. Inspired by European scholarship, this project attempts to extend human rights-oriented analysis to conflict of laws in the United States. It proposes a conceptual framework for understanding the relationship between human rights and conflict of laws in the abstract, applies the framework to conflict of laws in the United States, and offers comparative insights.
The presentation will be followed by open discussion. All are welcome. More information and sign-up here.
If you want to be invited to these events in the future, please write to veranstaltungen@mpipriv.de.