Enforcement of a foreign judgment
This table sets out which enforcement treaties/conventions a jurisdiction is signatory to.
This table has been derived from the Country Q&As of the multi-jurisdictional guide to dispute resolution. For a full list of jurisdictional Q&As visit www.practicallaw.com/dispute-mjg
What enforcement treaties/conventions is your jurisdiction a signatory to?
Enforcement of Foreign Judgments see Judgments (Reciprocal Enforcement) Act 1958, the Judgments Extension Order 1956 and the Judgment (Reciprocal Enforcement) Australia Order 1988 together with section 27 above.
Enforcement of foreign arbitral awards is straightforward, as Bermuda has the benefit and burden of the obligations in the New York Convention 1958.
The procedure to enforce a foreign award is always the same, regardless of the country where the award was made.
British Virgin Islands
Under the Reciprocal Enforcement of Judgment Act 1922, money judgments from the High Court of England and Wales and the Court of Session in Scotland, as well as the following jurisdictions (among others) can be enforced:
Money judgments from other jurisdictions, including the US, are enforceable at common law.
Only The Foreign Judgments Reciprocal Enforcement (Australia and its External Territories) Order 1993, although judgments obtained in jurisdictions subject to the Foreign Judgments Reciprocal Enforcement Law (1996 Revision) (Enforcement Law) can be registered in the Cayman Islands within six years of being obtained.
Cyprus is a member of the EU and all EU enforcement procedures are available.
The registration of judgments obtained in the UK is governed by the Foreign Judgments (Reciprocal Enforcement) Law 1935 and the rules made under the Law by an Order in Council.
Cyprus is also bound by bilateral treaties relating to the recognition and enforcement of foreign judgments with Bulgaria, China, Germany, Greece, Hungary, Poland, Russia, Serbia and Syria, and it is a signatory to various multilateral conventions relating to the recognition and enforcement of foreign judgments.
None. Enforcement of foreign judgments is permissible:
Indian courts have jurisdiction only with regard to countries that are notified under Section 44 A (Execution of decrees passed by Courts in reciprocating territory) of the Civil Procedure Code, 1908.
The following are reciprocating territories. For non-reciprocating countries, see Question 29, Dispute Resolution multi-jurisdictional guide.
A foreign judgment is recognised if it is final and satisfies all of the following requirements:
None. Enforcement of foreign judgments is permissible under the Judgments (Reciprocal Enforcement) (Jersey) Law 1960 (including England and Wales) and by common/customary law (including US).
New York Convention.
Judgments of countries not covered by the above instruments, including US, are enforceable through a special procedure (reciprocity is a substantive requirement).
2007 Lugano Convention.
The Reciprocal Enforcement of Foreign Judgment Act provides for reciprocal enforcement of judgments of:
UK (England & Wales)
Administration of Justice Act 1920 covers the enforcement of judgments from, among others:
United Arab Emirates