Recognition and enforcement of foreign judgments
In international situations, it frequently happens that a decision rendered by a foreign judge needs to be recognised or enforced in France.
Depending on the case, only the recognition of the foreign judgment will be sought. This is the case, for example, of a divorce that one wishes to transcribe into French civil status, without there being any other measures to enforce.
However, the Public Prosecutor's Office may oppose the transcription, particularly if it considers that the foreign decision is contrary to French international public policy (ordre public international). In such cases, it will be necessary to resort to an exequatur procedure, which will make the foreign judgment enforceable in France.
An exequatur will also often be necessary in the case of a foreign adoption judgment, in particular if the transcription into French civil status is refused or if the adopted person is to acquire French nationality.
The international rules applicable vary according to whether the foreign judgment for which recognition or enforcement is sought was given in a European Union State or in a State linked to France by a bilateral convention. Otherwise, French ordinary law will apply.
An attorney familiar with the applicable rules will be necessary to carry out these complex procedures.
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