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2007
Abstract An arbitral award which is issued abroad is deemed to be foreign. This follows from the first paragraph. Both the Model Law and the New York Convention are based on the same principle as the Act, namely that the nationality of the award is determined on a territorial basis.1 Conversely, an award is deemed to be Swedish if it is ...
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Abstract An arbitral award which is issued abroad is deemed to be foreign. This follows from the first paragraph. Both the Model Law and the New York Convention are based on the same principle as the Act, namely that the nationality of the award is determined on a territorial basis.1 Conversely, an award is deemed to be Swedish if it is ...
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Recognition and Enforcement of the Award
2005Abstract An award is no more than a piece of paper and the obtaining of an award by one party does not guarantee payment from the other party. A party who succeeds in obtaining an award in its favour may therefore have to enforce that award. The enforcement of an award can only be done through national courts.
Andrew Tweeddale, Keren Tweeddale
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Part III Recognition and Enforcement, 16 Recognition and Enforcement of Judgments: Introduction
2017This chapter considers the recognition and enforcement of judgments under Brussels 2012, Lugano 2007, and the Hague Convention. The relevant provisions are in Chapter III of Brussels and Lugano (and for authentic instruments and court settlements, Chapter IV); in Hague the relevant provisions are in Chapter III. These provisions apply only to judgments,
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2014
The invocation of one of the rights guaranteed against the recognition and enforcement of foreign judgments is the subject of this chapter. It is, in principle, well established that the recognition and enforcement of foreign judgments can (also) be denied on the basis of Article 6(1) ECHR. This would be the case if, for example, the proceedings abroad
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The invocation of one of the rights guaranteed against the recognition and enforcement of foreign judgments is the subject of this chapter. It is, in principle, well established that the recognition and enforcement of foreign judgments can (also) be denied on the basis of Article 6(1) ECHR. This would be the case if, for example, the proceedings abroad
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Comparative Recognition and Enforcement
2022This book provides the first detailed analysis of recognition and enforcement of foreign judgments and awards in civil and commercial matters from a transnational perspective. This perspective facilitates greater understanding of the present state of recognition and enforcement and offers insight into the establishment and operation of key modern ...
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Recognition and Enforcement of Judgments
1996Abstract Should judgments be purely territorial, with no effect outside the rendering state? I did not believe anyone today would take that position, until I learned that, absent a treaty, that is the law in as generally enlightened and internationalist countries as the Netherlands, Norway, and Austria.
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Recognition and Enforcement of Judgments
2008Abstract It has already been seen that, in a case involving a protected consumer contract under the Brussels I Regulation, a consumer who decides to litigate a claim against a supplier domiciled in another EU member has a choice between: (a) bringing the claim in the supplier’s home forum and (if necessary) proceeding to enforce the ...
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4 - The Commonwealth Model and Common Law Recognition and Enforcement
2022Drossos Stamboulakis
exaly

