In the course of an insolvency administration, a court may be asked to make an order against an individual requiring him to pay damages for wrongs done to the company, or to make restitution of sums wrongly received from the company. The individuals may be former officers of the insolvent corporation, or persons granted unfair preferences, and so forth. When the writ or demand is made, a defendant who is outside the territory of the court administering the insolvency may be tempted or advised to ignore the demand. English private international law holds that a foreign judgment in personam will be recognised if the defendant was present within the foreign jurisdiction when proceedings were begun, or submitted to the jurisdiction of the foreign court; and that a foreign judgment in rem will be recognised if the res was within the territorial jurisdiction of the foreign court. The significance of the judgment of the Court of Appeal in Rubin v. Eurofinance SA 1 is that we may now need to add a third category of foreign judgment to the list: a foreign judgment in insolvency, which will be recognised and enforced if made by a foreign court in a foreign main proceeding. If this is right, it will add to the sense that insolvency is different, and that the usual assumptions of private international lawyers do not apply to it. It is therefore a judgment of the greatest significance.