Recognition of Foreign Judgments

The prevalence of the rules and practices on the recognition and enforcement of foreign judgments gradually blurs the dividing line between 'recognition' and 'enforcement'. However, recognition is not an afterthought of enforcement. Recognition of Foreign Judgments explores how the courts in the selected jurisdictions, namely the European Union, England and Wales, and the United States, decide whether and to what extent to grant some preclusive effects to foreign judgments, while giving recognition to foreign judgments. These effects can possibly be relied on by foreign judgment holders to prevent a repetition of litigation of the same disputes or issues. To further reveal the practical significance of recognition of foreign judgments, this book explores some typical maritime cases and examines how the effects of certain maritime judgments can be extra-territorially realized by recognition, and how the mechanism of recognition of foreign judgments assists in achieving the objectives of the important legal mechanisms of maritime law. This book is particularly suitable for readers who have interests in private international law, transnational litigation, and maritime law.