14.01 Common law rules about the effect of foreign judgments

We will examine in Chapters 15 and 16 the schemes put in place by various statutes for giving effect in England to certain judgments of certain courts in certain foreign countries. What these statutory schemes have in common is that the foreign judgment may be registered at the High Court for enforcement in England as though it were a judgment of that court; under these schemes the foreign judgment itself can be enforced in England as though it were an English judgment. It is little wonder that such an effect can be justified and put in place only by statute, and that these statutes generally serve as the filter, as well as the vehicle, to give effect in England to the provisions of an international agreement, whether informal,1 or bilateral,2 or multilateral.3