18.01 It was said previously that the general rule in Brussels and Lugano is that all judgments from other Member States or Lugano States must be recognized unless there is a reason why they should not be. In this chapter, we discuss those reasons.1 18.02 The grounds for refusal set out in the instruments apply to both recognition and enforcement of a judgment. However, in the case of enforcement, the judgment debtor may also invoke grounds that apply under national law for the non-enforcement of national judgments—for example, that the judgment has been...
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