15.01 General

‘Enforcement of foreign judgments’ at common law is, as has been explained in the previous chapter, something of a mis-description: the matter before the English court may begin with and rely on a foreign judgment, but it is in fact a consequent, derivative, English judgment obtained on the basis of it which is enforced: the common law does not enforce foreign judgments as judgments, but allows the foreign judgment to pave the way for the judgment creditor to obtain an English judgment and to enforce that. It may be a matter of form more than substance, but it is an important matter of form.