Book contents
- Comparative Recognition and Enforcement
- Comparative Recognition and Enforcement
- Copyright page
- Contents
- Foreword
- Preface
- 1 Introduction
- Part I Transnational Recognition and Enforcement
- 2 ‘Global’ Recognition and Enforcement Approaches
- 3 Uniform Recognition and Enforcement in Europe
- 4 The Commonwealth Model and Common Law Recognition and Enforcement
- 5 Comparative Analysis of Recognition and Enforcement
- Part II Towards Increased Prospects for Judgments Recognition and Enforcement?
- Bibliography
- Index
4 - The Commonwealth Model and Common Law Recognition and Enforcement
from Part I - Transnational Recognition and Enforcement
Published online by Cambridge University Press: 10 November 2022
- Comparative Recognition and Enforcement
- Comparative Recognition and Enforcement
- Copyright page
- Contents
- Foreword
- Preface
- 1 Introduction
- Part I Transnational Recognition and Enforcement
- 2 ‘Global’ Recognition and Enforcement Approaches
- 3 Uniform Recognition and Enforcement in Europe
- 4 The Commonwealth Model and Common Law Recognition and Enforcement
- 5 Comparative Analysis of Recognition and Enforcement
- Part II Towards Increased Prospects for Judgments Recognition and Enforcement?
- Bibliography
- Index
Summary
Chapter 4 analyses the Commonwealth-driven approach to reciprocal recognition and enforcement, referred to in this book as the ‘Commonwealth Model’. At its core, the Commonwealth Model is a statutory judgment registration system that is premised upon British dominion, seconded, only where historical ties (but not dominion) extends, by reciprocity. Because this approach substantially replicates or relies for efficacy on its common law underpinnings, this chapter includes an analysis of these underlying common law foundations and approaches to recognition and enforcement.
Keywords
- Type
- Chapter
- Information
- Comparative Recognition and EnforcementForeign Judgments and Awards, pp. 83 - 119Publisher: Cambridge University PressPrint publication year: 2022