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Foreign Judgments and the Relationship between Direct and Indirect Jurisdiction

Richard Garnett

International & Comparative Law Quarterly2025https://doi.org/10.1017/s0020589325101000article
ABDC A*
Weight
0.37

Abstract

A key issue in the recognition and enforcement of foreign judgments is jurisdiction, with a distinction drawn between ‘direct’ jurisdictional rules, which are applied by the court of origin at the time of initial adjudication, and ‘indirect’ rules applied by a court at the recognition and enforcement stage. While some commentators and national laws suggest that no jurisdictional ‘gap’ should exist between direct and indirect rules, in this article it is contended that, outside the context of a federal system or international convention with uniform rules, no compelling justification exists for eliminating the gap.

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https://doi.org/https://doi.org/10.1017/s0020589325101000

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@article{richard2025,
  title        = {{Foreign Judgments and the Relationship between Direct and Indirect Jurisdiction}},
  author       = {Richard Garnett},
  journal      = {International & Comparative Law Quarterly},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.1017/s0020589325101000},
}

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Foreign Judgments and the Relationship between Direct and Indirect Jurisdiction

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Evidence weight

0.37

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.16 × 0.4 = 0.06
M · momentum0.53 × 0.15 = 0.08
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.