14 avril 2021
Gide Alert | Brexit | EU/UK | Cross-Channel Enforcement of Judgments
The recast Brussels Regulation, No.1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (Brussels Recast), is now at an end in English law. In this note, Rupert Reece and Daniel Holman from Gide's International Dispute Resolution group in London summarise the changes this means for the recognition and enforcement in England and Wales of judgments rendered by courts in other countries, focusing on judgments of French courts in particular.
In short, we have taken a step backwards. The UK's departure from the EU throws up significant hurdles to the mutual recognition and enforcement of court decisions, hurdles which did not exist under the Brussels Recast.
Click on the PDF below to read this Client Alert in full.