Moving towards harmonisation in the recognition and enforcement of foreign judgment rules in Asia
This paper provides a comparative overview of the laws on the recognition and enforcement of foreign judgments in ASEAN and Australia, China, India, Japan and South Korea. It considers the principles which are shared in common and the significant differences in the laws on foreign judgments in the r...
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| Format: | text |
| Language: | English |
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Institutional Knowledge at Singapore Management University
2020
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| Online Access: | https://ink.library.smu.edu.sg/sol_research/3108 https://ink.library.smu.edu.sg/context/sol_research/article/5066/viewcontent/moving_towards_Accepted_version_for_SMU_InK.pdf |
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| Institution: | Singapore Management University |
| Language: | English |
| Summary: | This paper provides a comparative overview of the laws on the recognition and enforcement of foreign judgments in ASEAN and Australia, China, India, Japan and South Korea. It considers the principles which are shared in common and the significant differences in the laws on foreign judgments in the region. This paper argues that the laws which are canvassed here share many principles, albeit the interpretation on certain aspects may differ. Though differences exist, the differences are becoming less sharp. Further, there is a practical need for harmonisation in the region given the plans for closer economic integration in the region. This paper argues that harmonisation is possible and should be pursued. |
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