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6 Foreign Judgments

From: Private International Law in English Courts

Adrian Briggs

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2021. All Rights Reserved.date: 20 September 2021

Subject(s):
Recognition and enforcement of foreign judgments — Jurisdiction under the Common Law Rules — Common law recognition — Overcoming foreign judgments obtained in breach of contract — Jurisdiction under the Lugano Convention — Jurisdiction under the Brussels I Regulation — Applicable law — Public policy — Evidence
6.01 The law on foreign judgments is complex only in the sense that it is fragmentary, but it is so fragmentary that it defies elegant explanation.1 On the footing that the first thing anyone concerned with a foreign judgment, or possible foreign judgment, needs to know is which of the several schemes is the one which will deal with the effect which this particular foreign judgment will have in England, it is helpful to start with a summary. 6.02 Several schemes have been created by legislation to deal with foreign judgments; and where legislation has not...
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