New Dawn for UK Judgment Enforcement

In a recent article authored by CDR News, Chiraag Shah shared his insights on the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (the Convention) that came into force in the UK on July 1, 2025. The Convention aims to facilitate the international circulation of judgments between states that have ratified the Convention and establishes common rules for recognizing and enforcing judgments, enhancing legal certainty and access to justice in cross-border transactions.

When asked whether more jurisdictions signing up to the Convention would improve its effectiveness, Chiraag agrees: “Some of the countries which would have a significant impact and likely pull other countries into signing up and/or ratifying the convention would be the US and China […] and key economic players in Asia and Africa.”

Chiraag also commented that the exclusion of interim remedies from the scope of the Convention makes sense: “The enforcement of interim measures that are subsequently overturned after a full trial would simply add an unnecessary level of complexity and inefficiency.”

However, Chiraag commented that there are uncertainties as to how interim measures may be interpreted by different courts, for example in relation to interim payments: “Ultimately, given that the convention was over two decades in the making, much thought has already gone into its scope and limitations – and whilst there may be scope to extend it in the future, such change is unlikely to come any time soon.”

Read the full article.