16.01 Registration of foreign judgments under the 1982 Act

Whereas the 1920 and 1933 Acts, examined in the previous chapter, allow a foreign judgment to be registered and enforced as such, rather than allowing or requiring it to be used as the basis for obtaining an English judgment which can then be enforced, the grounds on which registration under those Acts may and may not be ordered are, in substance, closely related to the rules of the common law. The 1982 Act, by contrast, was primarily devised for giving effect in England, by registration, to judgments falling under the Brussels Convention, the Lugano Convention, and the original Brussels I Regulation, 44/2001.1 At the same time, it was adapted to provide the mechanism for dealing with judgments from other parts of the United Kingdom and (though this is now strangely unclear) from Gibraltar.