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9 Foreign Judgments

From: Agreements on Jurisdiction and Choice of Law

Adrian Briggs

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 14 July 2024

Common law recognition — Judgments from designated court under dispute resolution agreement — Foreign judgments obtained in breach of jurisdiction agreement — Overcoming foreign judgments obtained in breach of contract — Recognition and enforcement of foreign judgments – Brussels and Lugano Conventions — Article 23
9.01 There are several sources of law on the recognition and enforcement of foreign judgments, but in essence the common law (and statutes which have based themselves on its principles) and the Brussels I Regulation (and the Conventions which preceded it) constitute two broad approaches to the question of whether, when, and how foreign judgments take effect in the English legal order. 9.02 At common law, the party seeking recognition of the judgment needs to show that, as a matter of English law, the foreign court was competent to give a judgment which the other...
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