ABSTRACT
This chapter focusses on recognition and enforcement of judgments in cross-border insolvency proceedings. It explains that mutual trust between the national courts of the Member States is the basis for the rule of automatic recognition, which is vital for effective recognition and enforcement of judgments. It also argues that the grounds for non-recognition of judgments should be reduced to the minimum. The only ground for non-recognition of a judgment in the EU insolvency law is public policy. This chapter explains the notion of public policy in the EU insolvency law and argues that it shall be interpreted narrowly and only gross violation of human and other rights should lead to non-recognition of judgments.
