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Dubai Courts on the Recognition of Foreign Judgments: “Recognition” or “Enforcement”? – that’s the Problem!

Conflict of Laws

The following case, very recently decided by the Dubai Supreme Court, is nothing but one of many examples which show how misconceptions and confusion regarding the notion of “recognition” would lead to unpredictable results ( cf. e.g., Béligh Elbalti, “Perspective of Arab Countries”, in M. (eds.), 1983-184ff). 338/2021 of 27 October 2021 ).

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Anti-enforcement injunction granted by the New Zealand court

Conflict of Laws

For litigants embroiled in cross-border litigation, the anti-suit injunction has become a staple in the conflict of laws arsenal of common law courts. This was the scenario facing the New Zealand High Court in the recent case of Kea Investments Ltd v Wikeley Family Trustee Limited [2022] NZHC 2881.

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Application of Singapore’s new rules on service out of jurisdiction: Three Arrows Capital and NW Corp

Conflict of Laws

Application of Singapore’s new rules on service out of jurisdiction: Three Arrows Capital and NW Corp The Rules of Court 2021 (‘ROC 2021’) entered into force on 1 April 2022. The Liquidators in turn sought orders from the BVI court that those assets were owned by the defendant and subject to the BVI Liquidation proceedings.