ABSTRACT
Recognition and enforcement of foreign judgments in Switzerland are subject to different legal provisions with different scopes of application. It should also be noted that the 26 Cantons of the Swiss Federation have largely retained legislative authority in the areas of civil procedural law. Federal procedural law will apply only where it is absolutely necessary for the uniform application of federal substantive law. Article 27 of the Lugano Convention lists several grounds according to which a foreign judgment will not be recognised. Swiss public policy may be violated where recognition would lead to a result which would be manifestly incompatible with fundamental principles of Swiss law. The distinction between judgments for the payment of money and non-monetary judgments has been made because in Switzerland the enforcement of monetary obligations is governed by federal law whereas the enforcement of other obligations is normally governed by cantonal law.
