Recognition of Jurisdictional Determinations by Foreign Courts
Journal of Private International Law | Taylor & Francis (Routledge) | Published : 2019
Parties have occasionally sought to use ﬁndings on jurisdiction made by a court in one country to preclude re-litigation of the same matter elsewhere. In common law countries the traditional means by which this tactic has been employed is the doctrine of issue estoppel. The aim of this article is to assess the extent to which jurisdictional determinations by foreign courts can have binding effects in other countries.