Must A Foreign Judgment Be Registered Before Being Relied On As A Petitioning Debt?

The Court of Appeal of England and Wales ("EWCA") recently handed down its decision in Servis-Terminal LLC v Valeriy Ernestovich Drelle [2025] EWCA Civ 62 clarifying that, as a matter of English law, an "unrecognised" foreign judgment cannot be relied upon as a basis to commence insolvency proceedings. By "unrecognised" in this context we mean a foreign judgment that has not been registered/recognised pursuant to a statutory procedure nor sued upon for enforcement at common law. This decision may have clarified the position in England and Wales but how impactful will it be on the position in Hong Kong?

Background of the Drelle case

Valeriy Drelle was the former CEO and a shareholder of Servis-Terminal LLC, a Russian company that had been in liquidation in Russia since April 2017 (the "Company"). In 2019, the Company's liquidator successfully obtained judgment in Russia against the debtor (Valeriy Drelle) for 2 billion roubles (approx. US$20 million). The debtor