| Summary: | Viewed from a general, global perspective, the recognition and enforcement of foreign judgments is not the rule. On the contrary, it generally requires a specific legal basis and justification that a country accepts the rulings of courts of other states and treats them like its own decisions. The main basis for such treatment is most often an international treaty or a supranational instrument (like, for instance, the Brussels Ibis Regulation1 or the revised Lugano Convention of 20072) that provides for the mutual acceptance of foreign court decisions among the states adhering to the respective instrument. In the absence of a specific bilateral or multilateral treaty or supranational instrument, the states autonomously formulate the conditions under which they recognise and enforce foreign judgments. In this respect, some countries follow a more generous, others a more restrictive, course. But, countries do not recognise foreign judgments without preconditions;3 every country provides for a certain type of control. Some, for instance, adhere to the principle of reciprocity. These countries recognise and enforce judgments of other countries only if the other country recognises and enforces their decisions..
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