Guernsey, as a Crown Dependency, is a separate jurisdiction from
the UK and has its own administrative, fiscal and legal systems. In
addition, Guernsey is not part of the EU or EEA, nor a signatory to
the Brussels or Lugarno Conventions. The result is that a foreign
judgment (including one from England and Wales) is not directly
enforceable in Guernsey simply by virtue of its existence. Foreign
judgments may, therefore, be enforced via one of two routes.
The Statutory Route
In Guernsey, there is a limited statutory regime for the
reciprocal enforcement of judgments. Under Part II of the Judgments
(Reciprocal Enforcement) (Guernsey) Law, 1957 (the "Reciprocal
Law"),
However, the extent of the Reciprocal Law is limited to
judgments from the superior courts of a small number of
jurisdictions- namely the UK, Jersey, the Isle of Man, the
Netherlands, Italy and Israel, Kingdom of the Netherlands, the
Netherlands Antilles (which was dissolved in 2010),