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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).

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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.

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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.

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News

Out now: Multinationals and Human Rights in Asia

Multinationals and Human Rights in Asia

Edited by Jason Ho Ching Cheung and Kazuaki Nishioka

This book investigates the availability in Asian jurisdictions of civil remedies against multinational businesses for human rights abuses.

It assesses whether the norms of the 2011 UN Guiding Principles on Business and Human Rights have taken root in Asia by first considering the international state of play. It then presents case studies of corporate governance and human rights in Asia, before examining emerging issues, and considering how Asia has dealt and can deal with corporate responsibility in connection with those matters. By way of conclusion, the book offers an action plan for implementing the UN Guiding Principles in Asia.

Jason Ho Ching Cheung is a Hong Kong barrister and New York attorney practicing from Albert Luk’s Chambers, Hong Kong and Yodoyabashi & Yamagami LPC, Japan. He is also a part-time lecturer at the Graduate School of Law and the Institute for the Liberal Arts at Doshisha University, Japan.

Kazuaki Nishioka is a specially appointed Associate Professor at the Graduate School of Law of Kobe University, Japan.

Apr 2026   |   9781509980406   |   328pp   |   Hbk   |    RRP: £100

Discount Price: £80

Order online at www.hartpublishing.co.uk  – use the code GLR BD8 to get 20% off!

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Bonn (Germany), 24/25 September 2026, Conference International Filiation Law in the EU

As already announced, there will be an international conference “International Filiation Law in the EU” dealing with questions of filiation law resulting from the EU Parenthood Proposal.

AMEDIP’s upcoming webinar: The HCCH Work Agenda in 2026. Opportunities and Challenges for AMEDIP presented by Ignacio Goicoechea (30 April 2026 – in Spanish)

The Mexican Academy of Private International and Comparative Law (AMEDIP) is holding a webinar on Thursday 30 April 2026 at 14:30 (Mexico City time – CST), 22:30 (CEST time). The topic of the webinar is: The HCCH Work Agenda in 2026. Opportunities and Challenges for AMEDIP, which will be presented by Ignacio Goicoechea, Representative of the HCCH Regional Office for Latin America and the Caribbean (ROLAC) (in Spanish). Read more

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