Mutual Recognition of Judgments - From the Hague to Lugano Conventions

Introduction

This virtual classroom seminar will consider five of the most encountered routes that litigants can use to obtain recognition of foreign judgments in England and Wales.

The session will also address how the availability of these routes has been affected by Brexit, as well as touching briefly on some, limited, general and high-level guidance on the steps that a judgment creditor with a judgment of a court or tribunal in England and Wales can take to get the judgment recognised in a foreign jurisdiction, and the consequences of recognition.

It is suitable for practitioners who would like to understand the range of tools that exist for the recognition and enforcement of foreign judgments in England and Wales, what steps can be taken to ensure that litigation commences in the intended jurisdiction, and which tool is right for the job at hand.

Given the breadth of material covered, this session is not aimed at those who are seeking an in-depth analysis of one of the conventions.

What You Will Learn

This live and interactive session will cover the following:

• How to identify in which jurisdiction litigation will take place
• Understand the current application and limits of five international conventions, including:
  • Hague Convention 2005
  • UNCITRAL Model Law on Cross-Border Insolvency
  • Lugano Convention
  • Brussels Judgments Regulation (Recast)
  • European Insolvency Regulation (Recast)
• The common law as it applies to the recognition of foreign judgments
• Limited practical guidance on how to enforce judgments obtained in this jurisdiction in foreign jurisdictions

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.