Views
The New Moroccan Framework on International Jurisdiction and Foreign Judgment Enforcement – A Preliminary Critical Assessment
I. Introduction
Finally out: the new Moroccan Code of Civil Procedure (Law No. 58.25), the preparation of which was previously announced on this blog, has been promulgated by Dahir (Royal Decree) No. 1.26.07 of 11 February 2026 and published in the Official Journal (Al-Jarida Ar-Rasmiyya) No. 7485 of 23 February 2026. The legislative process was fraught with difficulties, and the draft went back and forth several times before its final adoption earlier this year. The Code will enter into force six months after its publication, i.e. on 24 August 2026.
The Reception of Hilton v Guyot and Comity in the Recognition and Enforcement of Foreign Judgments in Anglophone Africa
Introduction
Hilton v Guyot, is the most influential case in the United States—and perhaps globally—on the use of comity as a basis for recognising and enforcing foreign judgments. In that case, Justice Gray of the United States Supreme Court defined comity as follows:
“No law has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived. The extent of which the law of one nation… shall be allowed to operate within the dominion of another nation, depends upon… the “comity of nations”…” Read more
No Exequatur Granted for a Panamanian Judgment in Greece Due to Public Policy Considerations [Piraeus Court of First Instance Case No. 2040/2026, Unreported]
INTRODUCTION
Following a significant hiatus, the public policy defense has re-emerged prominently in discussions surrounding the enforcement of foreign judgments, particularly in the context of a judgment issued by the Panama Maritime Court in 2024. The primary issue addressed by the Greek court was whether a foreign judgment could be recognized and enforced when the foreign court denied appellate proceedings due to the failure to post a security deposit that was both substantial and necessary for the appeal process.
News
Choice of Law Dataverse Launch — Online Event
The announcement below is kindly provided by Agatha Brandão de Oliveira (University of Lucerne, Switzerland)
After several years of intensive work, the Choice of Law Dataverse (CoLD) is ready to be shared with the wider community. The platform is an open-access resource gathering more than 17,000 data points — including legislation, court decisions, and other materials from 100 jurisdictions around the world. After collecting and processing this information, we have analyzed and systematized these choice-of-law rules into pedagogical country reports, now freely available for research, teaching, and practice. The project was recently awarded the Swiss National ORD Prize 2025.
We would be delighted to share this milestone with colleagues whose work continues to shape the field.
Date and Venue
28.04.2026 | Tuesday, 11.30 a.m. CEST, Online via Zoom
No registration required, calendar invitation with connection link attached
Participants are welcome to join the full programme or drop in for individual sessions — the Zoom link remains open throughout the day, and no registration is required.
Programme
11:30 – Understanding the Choice of Law Dataverse
Agatha Brandão (University of Lucerne, Switzerland) will demonstrate the platform’s main features.
12h – Party Autonomy: Sacred Principle or Legal Fiction?
A debate not to be missed between Professor Horatia Muir Watt (Sciences Po, France), Professor Béligh Elbalti (University of Osaka, Japan), and Professor Gérald Goldstein (Université de Montréal), moderated by Professor Daniel Girsberger (University of Lucerne, Switzerland), on the myths and enduring significance of party autonomy in international contract law.
13h – Permanent Bureau Remarks on Ten Years of the HCCH Principles
Raquel Peixoto offers a retrospective on a decade of the HCCH Principles on Choice of Law in International Commercial Contracts — what has been achieved, what lies ahead, and how this work intersects with CoLD.
14h – Bilateral Q&A
Participants may also request a 15-minute private session to explore the Dataverse for their own research purposes, ask questions about the project, or sign up as a specialist for their jurisdiction.
17h – Using the Dataverse for Advancing PIL Research
A session we particularly recommend for doctoral candidates and young researchers: Rorick Tovar (University of Lucerne, Switzerland), Solomon Okorley (University of Johannesburg, South Africa), and Ying Wang (Université de Montréal, Canada) discuss how CoLD supports comparative law and case law analysis in their own research.
Further information: cold.global/event/launch
For any questions, please contact agatha.brandao@unilu.ch.
We hope you can join us online for our launch event!
CoLD
Choice of Law Dataverse
University of Lucerne
JLMI – Call for papers – Issue no. 1/2027
This Call for Papers of the Journal of Law, Market & Innovation (JLMI) concerns the first issue to be published at the end of March 2027 and is devoted to the Securitisation of Supply Chains: Critical Raw Materials Between Energy Security and the Green Transition. This issue will be edited by the Editors-in-Chief of the JLMI (Lorenza Mola, Cristina Poncibò and Riccardo de Caria), along with Pritam Banerjee and Vishakha Srivastava as guest co-editor. You can find the call with all the details at the following link:
Postdoc Position “Fashion’s PLACE – Private (International) Law and Circular Economy”
The University of Edinburgh is recruiting a postdoctoral research fellow in private international law to work on an exciting new research project funded by the UKRI Arts and Humanities Research Council (AHRC) and the German Research Foundation (DFG) entitled “Fashion’s PLACE – Private (International) Law and Circular Economy”. The project explores the private law and private international law components of legal design for a just circular economy transition in global value chains. It takes the fashion industry as a case study, examining the journey of textiles from the places of production, via the marketplaces of consumption, to the places of disposal.