Views
Talaq Divorce Cases in the United States
Over the past several months, three state appellate courts in the United States have examined whether a “talaq” divorce obtained in another country is entitled to recognition as a matter of comity. In this post, I first survey the rules relating to the recognition of foreign divorce judgments in the United States. I then explain the concept of a talaq divorce. Finally, I discuss the cases.
Book Review: Choice of Forum Clauses in Asia (Lemuel L Lopez)
Choice of forum clauses are an important means of managing litigation risk in international commercial contracts. Their effectiveness, however, depends on how courts understand and enforce the parties’ agreement. This well-researched book offers a substantial comparative examination of that problem across seven Asian jurisdictions: Singapore, Hong Kong, Malaysia, the Philippines, China, Indonesia and Japan. Presented as the first work devoted to this particular comparative inquiry, it makes a valuable contribution to Asian private international law and offers insights that will interest readers working on choice of forum agreements elsewhere.
Zamzam on Egyptian Private International Law (in Arabic): Towards Reviving the Golden Age of Egyptian Private International Law
Private international law in Egypt has often been described as being in a state of stagnation. After enormous efforts by the government since the end of the 19th century, and particularly during the beginning of the 20th century, Egypt succeeded in developing a relatively comprehensive PIL framework, covering choice of law (Arts 10–28 of the 1948 Civil Code), international jurisdiction (Arts 28–35 of the 1968 Code of Civil and Commercial Procedure), and the enforcement of foreign judgments (Arts 296–301 the 1968 Code of Civil and Commercial Procedure), alongside other rules scattered across various pieces of legislation. While these rules could be considered relatively modern and well developed, and broadly in line with the general tendencies of comparative law at the time, they have since become quite outdated and, in many respects, old-fashioned. This, however, has not prevented Egyptian law from exerting considerable influence throughout the region, with more recent codifications often reproducing or adapting Egyptian solutions.
News
AAPrIL online seminar: Margaret Casey KC on “The 21st century global family – How science, law and a Convention tried and failed to establish a long-term relationship”
The Australasian Association of Private International Law (AAPrIL) is hosting its 4th seminar for 2026. The seminar is fully online and free to attend.
Margaret Casey KC will present on the topic, “The 21st century global family – How science, law and a Convention tried and failed to establish a long-term relationship”. The seminar will be chaired by Jack Wass.
Abstract:
Advances in medical science and changes in what is meant by ‘family’ mean that establishing parentage can be uncertain in domestic and international law. This creates issues for globally mobile families and lifelong status issues for some people. As numbers increasingly turn to surrogacy to form families, this creates legal challenges. Across Australasia, some jurisdictions (eg New Zealand and in Australia) regulate forms of surrogacy and try to accommodate citizens who travel overseas to implement surrogacy plans. However, parents returning home with a child born through surrogacy overseas may still confront problems in having their parentage recognised (with all the consequential rights and benefits for their child). International responses have been attempted. In 2016, Margaret Casey KC was appointed to the experts group established by the Hague Conference on Private International Law (HCCH) to recommend an acceptable set of rules for cross-border recognition of surrogacy and parentage. The final report was submitted to the HCCH Special Commission earlier this year. Although this report was substantial, consensus has not been reached and the project has been paused. In this seminar, Margaret will outline the context in which families are now being formed, the global nature of ‘family planning’, and resulting jurisdictional issues. She will comment on reform legislation being considered in New Zealand and whether or not it is fit for purpose for the modern family.
Details:
- Where: online only
- When: Thursday, 29 October 2026, 5:00 – 6:00pm AEDT (Australian time)
- Registration: free, following the details in the flyer below
Please share the invitation with anyone you consider may be interested.
Lindemann Fellowship for Private International Law: Call for Applications 2026
The Lindemann Fellowship was established in 2024 to support promising academics in Europe in the field of private international law.
Fellows are accepted for a three-year period, with new Fellows joining each year, as existing Fellows complete their tenure.
Book Launch: Commercial Private International Law in Southern Africa
The publication of the open-access Festschrift in honour of Professor Christopher F Forsyth KC, Commercial Private International Law in Southern Africa: Comparative and International Perspectives, has previously been announced on this blog.
Edited by Professor Jan L. Neels and Professor Eesa A. Fredericks, with the assistance of Dr Solomon Okorley, the volume brings together comparative and international perspectives on commercial private international law in Southern Africa.
To celebrate its publication, UJ Press, in collaboration with the editors and the Research Centre for Private International Law in Emerging Countries (RCPILEC), University of Johannesburg, is organising an online book launch, bringing together the editors, the dedicatee himself, and other distinguished guests.
The programme will include addresses by the University of Johannesburg’s leadership, contributions by the editors, and a reply by Professor Christopher F Forsyth and/or Mrs Gillian Charles.
The book launch will take place online. The details are as follows:
Date: 19 October 2026
Time: 13:00–14:00 SAST
Venue: Online
Queries: ujpress@uj.ac.za