Part III Jurisdiction, Foreign Judgments and Awards, 17 Recognition and Enforcement of Judgments Under the Brussels/Lugano System
Uglješa Grušić, Christian Heinze, Louise Merrett, Alex Mills, Carmen Otero García-Castrillón, Zheng Sophia Tang, Katarina Trimmings, Lara WalkerEdited By: Paul Torremans, James J. Fawcett
- Choice of law clauses — Jurisdiction under the Brussels-Lugano Regime
This chapter discusses the recognition and enforcement of judgments under the Brussels/Lugano system. It first considers the rules on recognition and enforcement under the Brussels I Recast, including grounds and non-grounds for refusal of recognition and enforcement. It then examines recognition and enforcement under the EC/Denmark Agreement and the Brussels Convention, the circumstances that merit the application of the rules on recognition and enforcement under the Lugano Convention, and the differences between the Lugano Convention and the Brussels I Recast with respect to recognition and enforcement of judgments. It also reviews the relevant provisions of the European Enforcement Order Regulation, the European Order for Payment Procedure Regulation, and the European Small Claims Procedure Regulation.