Tereza Kyselovská

Selected Issues of Recognition and Enforcement of ForeignJudgments from the Prespective of EU Member

RIV: CLANEK VE SBORNIKU JE NA CESTĚ K ZAŘAZENI DO WEB OF SCIENCE, BLIŽSI INFO ZATIM NEMAM. The issue of recognition and enforcement of foreign judgments is one of three key areas dealt with by private international law. Nevertheless, this issue falls not only within the scope of this legal discipline. For the actual enforcement of a foreign judgment, national procedural laws play an essential role. The interconnection between private international law and national procedural law makes this area of law very interesting issue for further legal research. In this article, we will outline the fundamental principles and concepts behind recognition and enforcement, historical development of national approaches to this issue, and the mechanism through which States take into account foreign judgments. Consequently, we will present, from the point of view of the EU Member States, sources of law for recognition and enforcement, including examples of relevant legal instruments; and resolution of possible conflicts between legal sources and their application.