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Hague 2019 in force in the UK – Good News for Commercial Parties

On 1 July 2025, the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (Hague 2019) entered into force in the United Kingdom. Hague 2019 is a multilateral...more

French Court Rejects Attempt to Use Civil Code to Usurp Brussels Recast Principles on Jurisdiction

In a decision issued on 2 April 2025, the French Cour de Cassation considered the validity of a jurisdiction clause under Article 25(1) of the Brussels Recast1. The French court rejected an attempt to invoke French national...more

Asymmetric Jurisdiction Clauses – The EU's Highest Court Gives Its View

On 27 February 2025, the EU's Court of Justice delivered its ruling on a case referred to it by the French Cour de Cassation concerning whether or not asymmetric jurisdiction clauses are valid as a matter of EU law;...more

Can a Foreign Judgment Debt Directly Give Rise to Insolvency Proceedings in England?

The Court of Appeal has held that seeking satisfaction of a foreign judgment debt using a statutory demand and the spectre of bankruptcy proceedings first requires the judgment to be recognised in this jurisdiction....more

Arbitration Act 2025 | Part 2: Key Improvements

The Arbitration Act 2025 is now an official new piece of legislation having received royal assent on 24 February 2025 ("2025 Act"). The new law, which refines and modernises the previous Arbitration Act 1996 ("1996 Act"),...more

English High Court enforces foreign judgment that is unenforceable in the jurisdiction of origin

The English High Court held in Invest Bank PSC v El-Husseini [2023] EWHC 2302 that a foreign judgment with res judicata effect in its jurisdiction of origin can be enforced in England at common law even if it is unenforceable...more

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