Enforcement Of Foreign (Non-EU) Judgments In Ireland - Current State Of Play?

The economic and commercial reality of the current business landscape means that many international commercial relationships have at some point become engaged in litigation resulting in a foreign judgment being handed down which is later sought to be enforced in Ireland. The extent to which a foreign judgment will be given recognition depends on the principles of private international law of the country of recognition.

In Ireland private international law has increasingly been the subject of various harmonisation measures adopted by the European Union. These have sought to standardise and simplify the rules regarding jurisdiction and the recognition and enforcement of judgments between the EU Member States. These measures include the Brussels 1 Regulations (Council Regulation (EC) No. 44/2001 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters) (as amended)), and the Lugano Convention (as between the EU Member States and