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2008
Abstract This chapter examines the effect of a foreign judgment in the English legal order and makes the first and most important point that a foreign judgment has, as such, no effect in England unless Parliament has made specific provision for its registration.
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Abstract This chapter examines the effect of a foreign judgment in the English legal order and makes the first and most important point that a foreign judgment has, as such, no effect in England unless Parliament has made specific provision for its registration.
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2019
This chapter discusses the recognition and enforcement of foreign judgements by Indian courts. Topics covered include refusal to recognize applicable Indian law; judgement opposed to natural or substantial justice; judgement obtained by fraud; sustaining a claim founded on a breach of Indian law; and foreign arbitral awards and foreign judgements based
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This chapter discusses the recognition and enforcement of foreign judgements by Indian courts. Topics covered include refusal to recognize applicable Indian law; judgement opposed to natural or substantial justice; judgement obtained by fraud; sustaining a claim founded on a breach of Indian law; and foreign arbitral awards and foreign judgements based
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Foreign Judgments and Foreign Status in Israel
The American Journal of Comparative Law, 1954THE ISRAEL LAW on recognition of foreign judgments is based upon the Common Law. Article 46 of the Palestine Order in Council, 1922, directs the local courts to apply the substance of the Common Law where local provisions do not extend or apply. There are, however, modifications due, in some slight measure, to local statutes, to a greater extent, to ...
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SSRN Electronic Journal, 2009
I am between flights at Dallas-Ft. Worth Airport, sitting on a comfortable chair outside of Starbucks and thinking about an editorial that ran in the New York Times a few weeks earlier. It seems that an author, resident in New York State, had authored a book accusing a Saudi sheik of financing terrorism.
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I am between flights at Dallas-Ft. Worth Airport, sitting on a comfortable chair outside of Starbucks and thinking about an editorial that ran in the New York Times a few weeks earlier. It seems that an author, resident in New York State, had authored a book accusing a Saudi sheik of financing terrorism.
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2014
The discussion of the impact of the ECHR on the issue of the recognition and enforcement of foreign judgments has been divided into two parts. This chapter focuses on the obligation to recognize and enforce foreign judgments which can be derived from the ECHR. The ECHR may not only obligate Contracting Parties to recognize and enforce foreign judgments,
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The discussion of the impact of the ECHR on the issue of the recognition and enforcement of foreign judgments has been divided into two parts. This chapter focuses on the obligation to recognize and enforce foreign judgments which can be derived from the ECHR. The ECHR may not only obligate Contracting Parties to recognize and enforce foreign judgments,
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Recognition of Foreign Judgments
2012The prefatory notes attached to the bill for the Foreign Judgments Recognition and Enforcement Law, 5717-1956 state, inter alia, that the situation in which “the rules for the recognition of foreign judgments current in Israel are drawn from English common law” is unsatisfactory, and should be changed by means of the proposed law.
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2016
This chapter deals with the recognition of enforcement of foreign judgments by English courts. The crucial question is not whether foreign judgments should be recognised and enforced in England but which judgments should be recognised and enforced. There are, broadly speaking, two theories.
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This chapter deals with the recognition of enforcement of foreign judgments by English courts. The crucial question is not whether foreign judgments should be recognised and enforced in England but which judgments should be recognised and enforced. There are, broadly speaking, two theories.
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Enforcement of Foreign Judgments Against a Foreign Sovereign
2012The immunity of a foreign sovereign from certain legal proceedings is one of the results of the recognition of the special status of a foreign sovereign state:
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