ABSTRACT
Introduction Disputes arising in international trade may be determined by foreign courts or arbitral tribunals. The question, therefore, arises as to the circumstances in which the English courts will recognise or enforce a foreign judgment or arbitral award. Recognition implies that the judgment or award is treated as conclusive of some matter which it determined. Enforcement implies that the judgment or award ordered something to be done, such as the payment of a sum of money, or the actual performance of a contract, or not to be done, as in the case of an injunction prohibiting the commission of a breach of contract or a tort, and that steps of an offi cial nature are taken with a view to ensuring that the order is complied with.
