By Raphaël MORENON
1 April 2025
Even if a foreign judgment seems perfectly official and final in its country of origin, it does not automatically receive a «visa» to produce its full effects in France. Whether you are seeking to enforce a foreign decision (via exequatur, as seen in our previous article) or are concerned by a judgment recognised by operation of law (such as a foreign divorce), the French judge always exercises an essential control before granting it full validity on our territory. He acts as a guardian, ensuring that the decision complies with fundamental standards. So what are these imperative conditions, these «filters» that the French judge systematically applies? Understanding these requirements is important for anticipating the chances of success or the potential difficulties involved in recognising a foreign judgment in France. We will look in detail at the four main points of control: the jurisdiction of the foreign court, the regularity of the proceedings...
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