Tag: conflict of judgments

Approach of Russian Courts to International Forum Shopping

Approach of Russian Courts to International Forum Shopping

Unlike in the United Kingdom or the United States, international forum shopping is rarely at issue in Russian case law or legal doctrine. However, disputes related to forum shopping do arise in Russia: it happens that the same disputes fall within the jurisdiction of national courts of several states, e.g. the national court of the […]

Recognition of Foreign Judgments in Russia: How to Reconcile Conflicting Judgments

Recognition of Foreign Judgments in Russia: How to Reconcile Conflicting Judgments

The CIS Arbitration Forum recently reported on a decision of the Moscow Circuit Commercial Court to enforce a judgment of the English High Court on the basis of reciprocity. We noted then that there was a growing trend of recognition of foreign court judgments on the basis of reciprocity (i.e. in the absence of a bilateral treaty). […]