Rubin: Enforcement Of US Judgments In England

UK Supreme Court decision confirms traditional rules on enforcement of all US judgments in England and reverses a significant liberalisation of cross-border bankruptcy law.

On 24 October 2012, the UK Supreme Court issued a judgment in the case of Rubin v Eurofinance SA,¹ reaffirming the English common law principles relating to enforcement of foreign judgments in England. Although foreign judgments may be enforced in England by a number of mechanisms and European Union regulations or international conventions apply in respect of certain countries, for a large number of jurisdictions (including the United States), it remains the case that English common law rules will determine whether such a judgment can be enforced.