6.4 Limitations to Enforcement of Foreign Judgments

The defences' catalogue (the exam's list): (1) the jurisdiction's defect (the foreign court's lack of the recognized jurisdictional base (the international competence's test — the foreign court's own view not decisive)); (2) the natural justice's breach (the foreign procedure's unfairness (the no-notice, the no-hearing)); (3) the fraud (the judgment's procurement by fraud); (4) the public policy (the foreign law's repugnance (Unit 4.3.4's bar)); (5) the penal-and-revenue character (the foreign penalties-and-taxes not enforced (Unit 4.3's bars)); (6) the res judicata-and-limits (the matter already decided; the subject's non-justiciability); (7) the reciprocity's requirement (the treaty-less enforcement's condition in some systems (the domestic-statute's craft)).