Tag: foreign courts

US Supreme Court Curtails Discovery in Foreign Arbitrations

US Supreme Court Curtails Discovery in Foreign Arbitrations

On June 13, 2022, the U.S. Supreme Court resolved the long-lasting circuit split and sided with the courts holding that arbitral tribunals deciding private commercial disputes and at least certain ad hoc panels in investor-state treaty arbitrations do not qualify to obtain discovery in the United States, under the broad U.S. discovery rules, for use […]

The New Hague Convention on the Recognition and Enforcement of Foreign Judgments: A New Competition to the New York Convention?
By 22 January, 2020 0 Comments Read More →

The New Hague Convention on the Recognition and Enforcement of Foreign Judgments: A New Competition to the New York Convention?

On 2 July 2019, the delegates of the 22nd Diplomatic Session of the Hague Conference on Private International Law (“Hague Conference”) adopted the Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (“Convention”). The discussions about potential ratification of the Convention by various countries (including the US and Russia) are […]

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Will Exercise of Jurisdiction by a Foreign Court Be Accepted in Russia?

Will Exercise of Jurisdiction by a Foreign Court Be Accepted in Russia?

The Presidium of the Russian Supreme Commercial Court is set to hear the first case in a while directly dealing with the enforcement of a foreign court judgment. The central issue is the following: can a Russian court assess the reasonableness of a foreign court’s decision to exercise jurisdiction in ruling on whether to recognise […]