Spontaneous Harmonization and the Liberalization of the Recognition and Enforcement of Foreign Judgments

Abstract

This article deals with the recent developments relating to the recognition and enforcement of foreign judgments. It argues that, in the light of the recent developments that have been occurring in many countries and jurisdictions, the recognition and enforcement of foreign judgments have been very much liberalized so that in many legal system the law of foreign judgments have been, to a certain extent, spontaneously harmonized. This phenomenon is the result of the abolition or the alleviation, at a national level, of the restrictive requirements on the recognition and enforcement of foreign judgments either by court decisions or by legislative reform.

Keywords: Recognition and Enforcement of Foreign Judgments, Harmonization, Recent Developments

JEL Classification: K19, K33, K41