The Orams Case,the Judgments Regulation and Public Policy: An English and European Law Perspective

Abstract

Using as a starting point the landmark ruling of the European Court of Justice in Apostolides v. Orams this Article examines the interpretation of the concept of public policy and its concrete application in the jurisprudence of the English and other national and supranational courts as a bar to the recognition and enforcement of foreign judgments, with an emphasis on situations where the competing acts of unrecognized foreign states or governments are at stake.