Obstacles to Recognition and Enforcement in German Autonomous Civil Procedure Law de lege lata and de lege ferenda

Authors

  • Michael Sonnentag

Keywords:

Obstacles to recognition and enforcement, International Civil Procedure Law, German Law

Abstract

In German autonomous Civil Procedure Law still exist obstacles to recognition and enforcement of foreign judgement like the requirement of the reciprocity, the priority of domestic judgement and the jurisdiction of the foreign state according to domestic rules (“mirrow principle”). The article demonstrates the necessity of the abolition of these obstacles to recognition and enforcement.

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Author Biography

Michael Sonnentag

Privatdozent at the University of Frankfurt am Main, Germany.

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Published

2013-04-01

How to Cite

SONNENTAG, M. Obstacles to Recognition and Enforcement in German Autonomous Civil Procedure Law de lege lata and de lege ferenda. Civil Procedure Review, [S. l.], v. 4, n. 1, p. 21–35, 2013. Disponível em: https://civilprocedurereview.com/revista/article/view/46. Acesso em: 3 jul. 2024.

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Section

Artigos