Recognition and enforcement of foreign judgments in the Law of Iran and England: a comparative study

Resumo

The aim of this study was to Recognition and Enforcement of Foreign Judgments in the Law of Iran and England: A Comparative Study. There are a lot of similarities and commonalities between the legal system of Iran and England in the field of recognition and enforcement of the foreign judgments including public discipline and conflicting judgments. Public discipline in England Law is more specific than that of Iran. Being a civil case of the judgment, impossibility of recognition, enforcement of tax and criminal judgments are among the similarities of the two systems. On the other hand, reciprocity, precise of the foreign court, and the jurisdiction governing the nature of the claim are among instances which are different in Iran and England legal systems on the recognizing of the enforcement of foreign judgments.