See Janet Walker, Recognition and Enforcement of Foreign Judgments
and Arbitral Awards in Canada [section]64.
In the absence of an international treaty governing the recognition and enforcement of foreign judgments
by domestic courts, the National Conference of Commissioners on Uniform State Laws drafted the UFMJRA in 1962 to unify the approach of U.
For purposes of a proposed federal statute, it was clear that appropriate and/or inappropriate bases of judicial jurisdiction for purposes of the recognition and enforcement of foreign judgments
would need to be identified.
Prior to the effective date of the Florida Enforcement of Foreign Judgments
Act, October 1, 1984, these direct proceedings were not available to enforce a foreign judgment.
See ENFORCEMENT OF FOREIGN JUDGMENTS
WORLDWIDE 216--17 (Charles Platte & William G.
In 1984, the Florida Enforcement of Foreign Judgments
Act was adopted, providing a simplified alternative procedure for domesticating a "foreign judgment"(41) and by amendment in 1994 the term "foreign judgment" has included the judgments of a "court .
Choice of Law, Comity, and the Enforcement of Foreign Judgments
in the United States
improve predictability in enforcement of foreign judgments
, (97) as well
A uniform set of rules on jurisdiction and the recognition and enforcement of foreign judgments
would also be necessary for the resolution of conflicts in cross-border business relations between independent states adhering to different traditions and concepts of international civil procedure laws.
101) This prohibition of a revision au fond, which is now a standard rule in many domestic enforcement schemes,(102) would facilitate the enforcement of foreign judgments
granting relief that is unknown in the forum in which enforcement is sought.
Guidance on dispute resolution, including choice of law, jurisdiction, alternative dispute resolution, arbitration procedure, enforcement of foreign judgments
and arbitration awards
have edited contributions by noted Greek legal scholars and legislators on such subjects as the Greek Constitution, commercial and maritime law and the enforcement of foreign judgments
88) Courts generally can refuse the recognition and enforcement of foreign judgments
on the basis of public policy.
It examines comparative issues of jurisdiction in the United States and Europe, choice-of-court agreements, conflicts of jurisdiction, choice of law, party autonomy and mandatory rules in contract law, regulating business activities, protecting employees, conserving foreign currency, and recognition and enforcement of foreign judgments
Remaining chapters address service of US process on foreign persons, extraterritorial discovery and taking evidence abroad, recognition and enforcement of foreign judgments
, and international commercial arbitration and US courts.