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What Limitation Regime applies to a foreign judgment?
What Limitation Regime applies to a foreign judgment?
There are traditionally two ways in which foreign judgments can be recognised in England & Wales:
Statutory registration; and
Common law.
It is common ground that the Lebanese judgment does not fall into either of the statutory regimes available. It is also common ground that the Lebanese judgment has not undergone the common law conversion to an English judgment by way of a Part 7 claim.
- Heading
- Introduction
- Basic Principles
- The Background
- Reasons for restraining Presentation
- Limitation point
- What Limitation Regime applies to a foreign judgment?
- The statutory regime
- The Administration of Justice Act 1920 (“ the 1920 Act ”)
- Foreign Judgments (Reciprocal Enforcement) Act 1933 (“ the 1933 Act ”)
- The Common Law Regime
- Status of unregistered/unrecognised foreign Judgment
- Limitation
- Acknowledgement
- Satisfaction
- Stay
- Abuse of Process
- Conclusions