Mention three tests for the recognition and enforcement of foreign judgments , what are they ?
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ChatGPT
May 4
1. The test of jurisdiction: This test examines whether the foreign court had jurisdiction over the parties and the subject matter of the case in accordance with the principles of international law.
2. The test of due process: This test ensures that the foreign judgment was obtained through a fair and impartial legal process, with both parties having the opportunity to present their case and defend their rights.
3. The test of public policy: This test examines whether the enforcement of the foreign judgment would violate the public policy of the enforcing state, such as principles of justice, morality, or fundamental rights.
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Google Gemini AI
May 4
1. Reciprocate Test 2. Comity Test 3. Dual Enforcement - based on comity and reciprocity