The enforcement of foreign awards and decrees in India plays a crucial role in facilitating international trade and promoting foreign investment. Res judicata, a legal principle derived from Latin, meaning "a matter already judged," governs the execution of foreign judgments in Indian courts.

This research paper explores the concept of res judicata and its application to the execution of foreign awards and decrees in India. It delves into the legal framework, relevant case laws, and the challenges faced in enforcing foreign judgments. Additionally, the paper analyses the impact of the New York Convention and Indian statutes on the execution process. Overall, the objective is to provide a comprehensive understanding of the Res Judicata doctrine and its significance in executing foreign awards and decrees in India.

This research paper aims to provide valuable insights into the Res Judicata doctrine and its application to the execution of foreign awards and decrees in India. By examining the legal framework, case laws, challenges, and recent developments, this analysis will contribute to a better understanding of the complexities surrounding the enforcement of foreign judgments

Introduction:
An essential aspect of international trade and investment is the enforcement of foreign judgements and decrees in India. The principle of res judicata, derived from Latin and meaning "a matter already judged," governs the execution of foreign judgements in Indian courts in a significant way. Res judicata is a fundamental legal doctrine that promotes finality and prohibits re-litigation of previously adjudicated matters.

Execution of foreign awards and decrees requires the recognition and enforcement of foreign court or arbitral tribunal judgements. In India, the Code of Civil Procedure (CPC) regulates the execution of foreign judgements. However, the application of res judicata to foreign judgements and decrees presents unique difficulties and complexities.

India is a signatory to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which contributes to the framework for enforcing foreign awards in the country. The New York Convention establishes a uniform regime for the recognition and enforcement of arbitral awards in a variety of jurisdictions, including India[1]. Its provisions play a significant role in promoting international commercial arbitration and facilitating the execution of foreign arbitral awards in India.

In India, the execution of foreign awards and decrees is subject to numerous procedural requirements and conditions. Indian courts play a crucial role in determining the enforceability of foreign judgements and ensuring compliance with natural justice principles and public policy. When evaluating the execution of foreign awards and decrees in India, the courts consider jurisdiction, due process, and compatibility with Indian law.

Numerous landmark decisions have shaped the jurisprudence surrounding the execution of foreign awards and decrees in India. These cases have established guidelines for evaluating the legality and enforceability of foreign judgements[2]. In the context of executing foreign awards and decrees, they provide crucial precedents and interpretations of the Res Judicata doctrine.

Despite the legal framework and judicial precedents, there are obstacles to the execution of foreign judgements in India. Practical challenges, conflicts between Indian and foreign laws, and policy and public interest concerns frequently complicate the enforcement process[3]. To ensure an effective and efficient execution regime, these obstacles necessitate ongoing discussions and reforms.

Legal Framework:
The execution of foreign awards and decrees in India is governed by the relevant provisions of the Indian Code of Civil Procedure (CPC) and the principle of res judicata. The Indian Code of Civil Procedure, enacted in 1908, is the principal law governing civil procedure in India . Section 13 of the CPC describes the principles of res judicata, which apply to both domestic and foreign judgements[4]. As a fundamental legal doctrine, res judicata prohibits the re-litigation of matters that have already been definitively adjudicated.

The Indian Code of Civil Procedure recognises and permits the execution of foreign judgements. Section 44A of the CPC provides a mechanism for the execution of superior court judgements in certain reciprocating territories[5]. Reciprocating territories are those countries or territories notified by the Indian government pursuant to Section 44A where Indian judgements are recognised and executed. Similar to the execution of domestic judgements, the execution process is streamlined in reciprocating territories.

In non-reciprocal territories, the execution procedure is governed by Section 13 of the CPC, which requires the judgement creditor to file a lawsuit based on the foreign judgement in order to obtain a new decree from an Indian court. The court will review the merits of the foreign judgement and may deny the decree if it deems it to be inconclusive, not based on the merits of the case, or contrary to public policy[6].

In addition to the CPC, the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards has a significant impact on the enforcement of foreign awards and decrees in India. India is a signatory to the New York Convention, which establishes a uniform regime for recognising and enforcing foreign arbitral awards[7]. The Convention provides a comprehensive legal framework for the enforcement of arbitral awards in multiple jurisdictions, including India.

By virtue of the 1996 Arbitration and Conciliation Act, the New York Convention is applicable in India. The Act's Section 44 recognises and enforces foreign arbitral awards as if they were court orders[8]. This recognition ensures that foreign arbitral awards are treated in the same manner as domestic judgements, permitting their execution and enforcement in India.

The CPC, particularly the principles of res judicata, as well as the provisions of the New York Convention and the Arbitration and Conciliation Act define the overall legal framework for executing foreign awards and decrees in India.

The New York Convention:
The New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, to which India is a party, plays a significant role in the execution of foreign awards in India. The Convention provides a comprehensive framework for the recognition and enforcement of foreign arbitral awards, facilitating international arbitration and promoting the finality and enforceability of arbitral awards. The New York Convention was adopted by the United Nations General Assembly in 1958 and has gained widespread acceptance globally. Its objective is to establish a unified regime for the recognition and enforcement of arbitral awards, promoting the effectiveness of international commercial arbitration as a means of resolving disputes.

India became a signatory to the New York Convention in 1960, and it was subsequently incorporated into Indian law through the Arbitration and Conciliation Act, 1996. Section 44 of the Act recognizes and enforces foreign arbitral awards as if they were decrees of an Indian court[9]. This provision ensures that foreign arbitral awards are treated on par with domestic judgments, allowing for their execution and enforcement in India.

The New York Convention sets out essential principles and procedures for the recognition and enforcement of foreign arbitral awards. It establishes a straightforward process for requesting recognition and enforcement, limiting the scope for review by national courts. The Convention requires contracting states to recognize and enforce arbitral awards made in other member states, subject to limited grounds for refusal. Under Article V of the New York Convention, a court may refuse to recognize and enforce a foreign arbitral award if certain conditions are met.

These grounds for refusal include matters such as invalidity of the arbitration agreement, lack of proper notice, incapacity of a party, and contravention of public policy. The New York Convention has significantly influenced the execution of foreign awards in India, providing a robust legal framework and promoting the finality and enforceability of arbitral awards. By ensuring that foreign arbitral awards are treated as enforceable judgments, the Convention has facilitated international trade and investment, promoting India's role as an arbitration-friendly jurisdiction.

Furthermore, the New York Convention has enhanced India's integration into the international arbitration community, fostering greater cooperation with other signatory countries. The Convention's principles of non-discrimination and equal treatment of foreign arbitral awards have encouraged parties to choose India as a seat for arbitration and have contributed to the growth of India's arbitration ecosystem. the New York Convention serves as a vital international instrument in the execution of foreign awards in India.

By providing a standardized framework for the recognition and enforcement of arbitral awards, the Convention enhances legal certainty, promotes international trade, and strengthens India's position as a favourable destination for international commercial arbitration.

Execution of Foreign Awards and Decrees in India:
The execution process of foreign awards and decrees in India involves specific procedures and conditions outlined by the Indian legal system. The Indian Code of Civil Procedure (CPC), along with relevant case laws and principles, governs the execution of foreign judgments in Indian courts. The execution procedure for foreign awards and decrees in India is outlined in Section 44A of the CPC . This section applies to judgments and decrees passed by superior courts in reciprocating territories, as notified by the Indian government (as of July 2023 - United Kingdom, Singapore, Bangladesh, Malaysia, New Zealand, Hong Kong and UAE). Reciprocating territories are countries or territories where Indian judgments are recognized and executed in a similar manner.

For judgments originating from reciprocating territories, the execution process is simplified. The judgment creditor can directly apply for execution by filing an execution petition before the appropriate court in India. The court treats the foreign judgment as if it were a decree passed by an Indian court and proceeds with the execution accordingly.

In contrast, for judgments originating from non-reciprocating territories, the execution process follows the principles of Section 13 of the CPC. Under this provision, the judgment creditor is required to file a suit in an Indian court based on the foreign judgment, seeking a new decree from the Indian court.

The court examines the merits of the foreign judgment and may refuse to grant the decree if it finds that the judgment is not conclusive, not given on the merits of the case, or is against public policy. Indian courts play a crucial role in the execution of foreign awards and decrees. They assess the jurisdictional competence of the foreign court, the validity of the foreign judgment, and compliance with principles of natural justice and public policy. The courts may refuse to execute a foreign judgment if it is found to be obtained by fraud, in violation of the principles of natural justice, or contrary to public policy considerations.

Case laws have further shaped the execution process of foreign awards and decrees in India. Landmark judgments such as the Bhatia International v. Bulk Trading S.A.[10] and the Balco v. Kaiser Aluminium Technical Services case[11]have established principles regarding the enforcement of foreign arbitral awards in India. These cases have clarified issues such as the applicability of Part I and Part II of the Arbitration and Conciliation Act, the extent of judicial intervention, and the public policy considerations in enforcing foreign awards.

Despite the legal framework and case laws, challenges persist in the execution of foreign judgments in India. Practical difficulties, conflicts between Indian and foreign laws, and concerns related to public policy and public interest can complicate the execution process. It is essential for courts and legislative bodies to address these challenges to ensure an effective and efficient execution regime.

In recent years, India has undertaken reforms to streamline the execution process and enhance its enforcement mechanisms. The adoption of the Insolvency and Bankruptcy Code, 2016, which recognizes and enforces foreign judgments related to insolvency proceedings, is one such notable development[12]. These reforms demonstrate India's commitment to providing an efficient and conducive environment for the execution of foreign awards and decrees.

In conclusion, the execution of foreign awards and decrees in India is guided by the provisions of the CPC, case laws, and principles of natural justice and public policy. The process varies depending on whether the foreign judgment originates from a reciprocating or non-reciprocating territory. While challenges exist, ongoing reforms and judicial decisions aim to improve the execution regime and promote the enforceability of foreign judgments in India.

Case Laws
The execution of foreign awards and decrees in India has been shaped by significant case laws that have established principles and guidelines for the recognition and enforcement of foreign judgments. The following landmark cases have played a crucial role in interpreting and clarifying the execution process of foreign awards and decrees in India.

1. Bank of Tokyo Ltd. v. M/s. Vysya Bank Ltd.[13]:
   In this case, the Supreme Court of India dealt with the execution of a foreign decree. The court held that a foreign decree can be enforced in India if it meets the requirements of Section 13 of the Indian Code of Civil Procedure. The judgment emphasized the importance of reciprocity and the need for the foreign judgment to be conclusive, given on the merits of the case, and not against public policy.
    
2. Satya v. Teja Singh[14]:
   In this case, the Supreme Court considered the issue of executing a foreign judgment involving immovable property in India. The court held that if a foreign judgment is based on rights in immovable property situated in India, it cannot be executed as a decree under Section 44A of the Indian Code of Civil Procedure. Instead, a separate suit must be filed in India to obtain a judgment on the basis of the foreign judgment.
    
3. Philips India Ltd. v. Bharat Heavy Electricals Ltd.[15]:
   This case dealt with the execution of a foreign judgment arising from a commercial dispute. The Supreme Court clarified that a foreign judgment can be enforced in India even if the original cause of action arose outside India. The court highlighted the importance of reciprocity and concluded that the judgment creditor is entitled to execute a foreign judgment in India as long as the jurisdictional requirements are met.
    
4. International Woollen Mills v. Standard Wool (UK) Ltd.[16]:
   In this case, the Supreme Court considered the enforceability of a foreign decree against a company that had undergone liquidation in India. The court held that the foreign decree could be enforced against the company during the liquidation process. The judgment emphasized that the execution of a foreign decree should not be hindered solely due to the existence of winding-up proceedings in India.
    
5. Bhatia International v. Bulk Trading S.A.[17]:
   In this case, the Supreme Court of India addressed the issue of whether Part I or Part II of the Arbitration and Conciliation Act, 1996, applies to the enforcement of foreign awards. The court held that Part I of the Act, which deals with domestic arbitration, would apply to international commercial arbitrations conducted in India unless expressly excluded. The judgment emphasized the significance of public policy considerations in enforcing foreign awards and established the principle that Indian courts can intervene in the enforcement of foreign awards under certain circumstances.
    
6. Balco v. Kaiser Aluminium Technical Services[18]:
   This case dealt with the issue of whether the seat of arbitration determines the jurisdiction of Indian courts over the enforcement of foreign awards. The Supreme Court held that the seat of arbitration would determine the applicability of Part I or Part II of the Arbitration and Conciliation Act, 1996. The court concluded that the seat of arbitration would confer exclusive jurisdiction on the courts of that country, and Indian courts would have a limited supervisory role in cases where the seat of arbitration is outside India.
    
7. Vijay Karia v. Prysmian Cavi E Sistemi SRL[19]:
   In this case, the Supreme Court clarified the scope of public policy considerations in the enforcement of foreign awards. The court held that the public policy exception should be narrowly interpreted, and enforcement should be refused only in exceptional circumstances where the enforcement of the award would be contrary to the fundamental policy of Indian law or against the principles of justice and morality.
    
8. Shriram EPC Limited v. Rioglass Solar SA[20]:
   This case addressed the issue of whether a foreign award can be enforced in India when the underlying contract containing an arbitration clause is not stamped as required under Indian stamp laws. The Supreme Court held that the failure to stamp the underlying contract does not affect the enforceability of the foreign award, as stamping requirements are independent of the arbitration agreement and do not render the award against public policy.

Challenges and Limitations
The execution of foreign awards and decrees in India is not without its challenges and limitations. While the legal framework and case laws provide guidance, several factors can complicate the execution process. The following are some of the key challenges and limitations associated with the execution of foreign awards and decrees in India.

• Procedural Complexities:
  The execution process for foreign awards and decrees in India involves navigating complex procedural requirements. The need to comply with specific filing procedures, documentation, and evidentiary rules can be challenging, particularly for parties unfamiliar with the Indian legal system[21]. These procedural complexities can result in delays and increased costs in the execution process.
   
• Conflicts of Laws:
  Conflicts of laws can pose challenges in executing foreign awards and decrees in India. Issues may arise when there are differences between Indian laws and the laws of the foreign jurisdiction from which the judgment originates. Such conflicts can create uncertainties regarding the recognition and enforcement of foreign judgments, requiring courts to carefully analyse the applicable laws and principles[22].
   
• Public Policy Considerations:
  The execution of foreign awards and decrees in India is subject to the public policy exception. Indian courts may refuse to recognize and enforce a foreign judgment if it is found to be contrary to the fundamental policy of Indian law, against principles of natural justice, or against morality. The application of the public policy exception can be subjective and lead to differing interpretations, potentially impacting the enforcement of foreign awards[23].
   
• Practical Difficulties:
  Practical difficulties can arise during the execution process, particularly in cases involving international parties and assets. Issues such as language barriers, differences in legal systems, and the enforcement of monetary judgments can pose challenges. Enforcement against assets located in India may require additional steps, such as tracing and identifying assets, which can prolong the execution process[24].
   
• Lack of Reciprocity:
  The effectiveness of executing foreign awards and decrees in India depends on the existence of reciprocal arrangements with other jurisdictions. While India has entered into reciprocal agreements with several countries, the absence of such agreements with certain jurisdictions can hinder the execution of foreign judgments. This lack of reciprocity can limit the enforceability of judgments from non-reciprocating territories[25].

Recent Developments
Recent developments have brought about significant changes and advancements in the execution of foreign awards and decrees in India. These developments aim to streamline the execution process, enhance enforcement mechanisms, and promote India as a favourable jurisdiction for commerce through the recognition and enforcement of foreign judgments.

1. The Commercial Courts, Commercial Division, and Commercial Appellate Division of High Courts Act, 2015[26]:
   The enactment of this Act introduced specialized commercial courts and divisions in India. These courts have jurisdiction over commercial disputes, including those arising from foreign awards and decrees. The establishment of dedicated commercial courts aims to expedite the execution process and provide specialized expertise in resolving complex commercial matters.
    
2. The Insolvency and Bankruptcy Code, 2016[27]:
   The Insolvency and Bankruptcy Code (IBC) introduced a comprehensive framework for the resolution of insolvency and bankruptcy matters in India. Under the IBC, foreign judgments related to insolvency proceedings are recognized and enforced. This development enhances the enforceability of foreign awards and decrees in insolvency cases and promotes a more efficient resolution of cross-border insolvency matters.
    
3. The Arbitration and Conciliation (Amendment) Act, 2019[28]:
   The 2019 amendment to the Arbitration and Conciliation Act brought significant changes to the arbitration regime in India. It aimed to promote institutional arbitration, streamline the arbitration process, and enhance the enforceability of foreign arbitral awards. The amendment introduced provisions to expedite the execution process and reduced the scope for excessive judicial intervention in the enforcement of foreign arbitral awards.
    
4. Digitalization and E-Filing:
   The Indian judiciary has embraced digitalization and e-filing systems, which have simplified and accelerated the execution process. Online filing of execution petitions and the availability of digital records have reduced procedural delays and improved accessibility. The adoption of technology has made it easier for parties to initiate and track the progress of execution proceedings.

Comparative Analysis
A comparative analysis of the execution of foreign awards and decrees in India can provide valuable insights into the similarities and differences between India's approach and that of other jurisdictions. Understanding the practices and procedures followed in other countries can help identify best practices and potential areas for improvement.

• United States:
  In the United States, the execution of foreign judgments is governed by the Uniform Foreign Money Judgments Recognition Act (UFMJRA) and the Uniform Foreign-Country Money Judgments Recognition Act (UFCMJRA). These acts provide a streamlined procedure for the recognition and enforcement of foreign judgments, enhancing the ease of execution[29]. Compared to India, the U.S. execution regime offers greater clarity and uniformity in the recognition and enforcement process.
   
• United Kingdom:
  In the United Kingdom (UK), the execution of foreign judgments is regulated by the common law principles of private international law. The UK has also implemented the Recast Brussels Regulation, which provides a comprehensive framework for the recognition and enforcement of foreign judgments within the European Union[30]. The UK's execution regime benefits from the harmonization of rules within the EU, enabling a more straightforward and efficient execution process.
   
• Singapore:
  Singapore has adopted the common law principles for the recognition and enforcement of foreign judgments. The country has enacted the Reciprocal Enforcement of Foreign Judgments Act, which facilitates the enforcement of judgments from certain designated territories. Singapore's execution regime is known for its efficiency, clear procedures, and strong commitment to upholding the rule of law[31]. The well-established legal infrastructure in Singapore contributes to the effective execution of foreign judgments.
   
• China:
  China has implemented the Civil Procedure Law, which governs the recognition and enforcement of foreign judgments. The execution of foreign judgments in China requires obtaining approval from Chinese courts. China follows a strict approach to enforceability and may refuse recognition or enforcement on public policy grounds or if the judgment violates Chinese law[32]. Compared to India, China's execution regime is more centralized, with a greater emphasis on court approval and control.

International Best Practices
To ensure an effective and efficient execution of foreign awards and decrees, several international best practices can be considered. These practices are aimed at promoting the recognition and enforcement of foreign judgments while minimizing procedural complexities and delays.

Model Laws and Conventions: Model laws and conventions play a crucial role in promoting harmonization and consistency in the execution of foreign judgments. For instance, the United Nations Commission on International Trade Law (UNCITRAL) has developed the Model Law on Recognition and Enforcement of Insolvency-Related Judgments, which provides guidance on the recognition and enforcement of foreign judgments in insolvency matters[33]. Jurisdictions can consider adopting such model laws to establish a comprehensive framework for executing foreign judgments.

Streamlined Procedures: Efficient and streamlined procedures can expedite the execution process. Implementing clear and concise filing requirements, standardized forms, and electronic systems for filing and tracking execution proceedings can reduce delays and enhance accessibility[34]. Jurisdictions should focus on simplifying procedural requirements while ensuring compliance with due process and fairness.

Specialized Courts and Divisions: Establishing specialized courts or divisions dedicated to handling commercial disputes and foreign judgments can significantly enhance the execution process. These specialized courts can develop expertise in dealing with cross-border matters and provide expedited and efficient resolution of disputes. For instance, the establishment of commercial courts in India has expedited the execution of foreign awards and decrees related to commercial disputes[35].

International Cooperation and Reciprocal Arrangements: Promoting international cooperation and entering into reciprocal arrangements with other jurisdictions facilitate the execution of foreign judgments. Bilateral or multilateral agreements can enhance the enforceability of foreign awards and decrees by establishing clear legal frameworks and recognition mechanisms[36]. Active participation in international initiatives and organizations can help jurisdictions stay updated with global developments and enhance their cooperation network.

Transparent and Predictable Legal Framework: A transparent and predictable legal framework is crucial for executing foreign judgments. Jurisdictions should ensure clarity in their laws and regulations governing the recognition and enforcement of foreign awards and decrees. Providing guidelines, guidelines, and explanatory notes on the interpretation and application of these laws can enhance predictability and promote consistency in decision-making[37].

Judicial Training and Exchange of Best Practices: Continuous judicial training programs and the exchange of best practices among judges and legal professionals are instrumental in improving the execution process. Training programs can focus on cross-border legal principles, the interpretation of international conventions, and the latest developments in the execution of foreign judgments. Platforms for sharing experiences and best practices facilitate the adoption of effective strategies.

Conclusion:
In India, the execution of foreign awards and decrees is governed by a comprehensive legal framework, which is supported by case laws and recent developments. Despite the existence of obstacles and restrictions, efforts have been made to streamline the execution process and improve the enforceability of foreign judgements. Comparative analysis and international best practises offer invaluable insights for future enhancements.

With provisions aligned with international standards such as the New York Convention, India's legal framework provides a solid foundation for the recognition and enforcement of foreign awards and decrees. Recent developments, including the establishment of specialised commercial courts, the enactment of insolvency laws, and amendments to arbitration legislation, demonstrate India's dedication to streamlining the execution procedure.

Nonetheless, obstacles remain, such as procedural complexities, conflicts of laws, public policy considerations, practical difficulties, and the absence of reciprocity. To address these challenges, ongoing efforts are required to streamline procedures, clarify the legal framework, and foster international cooperation.

International best practises provide invaluable direction for improving the execution process. Adopting model laws and conventions, streamlining procedures, establishing specialised courts, promoting international cooperation, ensuring a transparent and predictable legal framework, and facilitating judicial training and the exchange of best practises can all contribute to an effective and efficient execution regime.

Given the changing global landscape of cross-border trade and dispute resolution, efforts to improve the execution of foreign awards and decrees in India should continue. India can further strengthen its position as a favourable jurisdiction for the recognition and enforcement of foreign judgements by addressing the challenges and adopting international best practises, thereby promoting certainty, efficiency, and access to justice in cross-border transactions.

End-Notes:

1. United Nations Commission on International Trade Law (UNCITRAL), "Status of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards,"
2. Rajesh Sharma, "Enforcement of Foreign Arbitral Awards in India: Recent Developments," 11 SCJ 8 (2014).
3. Ajay Thomas, "Enforcement of Foreign Awards in India: Challenges and Solutions," International Business Law Journal, Vol. 3, Issue 1, pp. 22-30, 2020.
4. The Code of Civil Procedure, 1908, Section 13, Act No. 5 of 1908 (India).
5. The Code of Civil Procedure, 1908, Section 44A, Act No. 5 of 1908 (India).
6. Ibid.
7. Ibid.
8. The Arbitration and Conciliation Act, 1996, Section 44, Act No. 26 of 1996 (India).
9. Ibid
10. Bhatia International v. Bulk Trading S.A., (2002) 4 SCC 105.
11. Balco v. Kaiser Aluminium Technical Services, (2012) 9 SCC 552.
12. The Insolvency and Bankruptcy Code, 2016, Act No. 31 of 2016 (India).
13. Bank of Tokyo Ltd. v. M/s. Vysya Bank Ltd., (1988) 4 SCC 80.
14. Satya v. Teja Singh, (1975) 1 SCC 120.
15. Philips India Ltd. v. Bharat Heavy Electricals Ltd., (2013) 10 SCC 781.
16. International Woollen Mills v. Standard Wool (UK) Ltd., (2001) 3 SCC 706.
17. Ibid
18. Ibid
19. Vijay Karia v. Prysmian Cavi E Sistemi SRL, (2020) 4 SCC 17.
20. Shriram EPC Limited v. Rioglass Solar SA, (2018) 2 SCC 575.
21. Rakesh Kapoor, "Execution of Foreign Decrees in India: Challenges and Solutions," Legal Service India,
22. meet Naik and Nishit Dhruva, "Enforcement of foreign judgments and awards in India," Lexology,
23. Ramanuj Mukherjee, "Foreign Judgments in India: Execution & Challenges," iPleaders Blog,
24. Ashish Kabra, "Execution of Foreign Judgments and Awards in India," Bar & Bench, https://www.barandbench.com/columns/execution-of-foreign-judgments-and-awards-in-india
25. Ameeta Verma Duggal, "Enforcement of Foreign Judgments and Decrees in India: An Overview," Kluwer Arbitration Blog, https://arbitrationblog.kluwerarbitration.com
26. The Commercial Courts, Commercial Division, and Commercial Appellate Division of High Courts Act, 2015, Act No. 4 of 2016 (India).
27. ibid
28. ibid
29. Uniform Foreign Money Judgments Recognition Act, Uniform Law Commission, https://www.uniformlaws.org/committees/community-home?communitykey=ecbf7361-1ee9-4810-816b-83afcbf7c0f3&tab=groupdetails
30. Recast Brussels Regulation, European Commission, https://ec.europa.eu/info/law/cross-border-cases/judicial-cooperation/civil-matters/eu-rules-civil-cases_en
31. Reciprocal Enforcement of Foreign Judgments Act, Singapore Statutes Online, https://sso.agc.gov.sg/Act/REFJA1933
32. Civil Procedure Law of the People's Republic of China, The National People's Congress of the People's Republic of China, http://www.npc.gov.cn/npc/c30834/202009/1e29e350a5af4f4ea76076fd7610754f.shtml
33. UNCITRAL, "Model Law on Recognition and Enforcement of Insolvency-Related Judgments," https://uncitral.un.org/sites/uncitral.un.org/files/media-documents/uncitral/en/uncitral_texts/insolvency/2018Model_L
34. Ministry of Justice (UK), "Recognition and Enforcement of Foreign Judgments: A Guide for Businesses," https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/861076/recognition-enforcement-foreign-judgments-guide-business.pdf
35. High Court of Delhi, "Commercial Courts, Commercial Division and Commercial Appellate Division of High Courts Act, 2015," http://delhihighcourt.nic.in/writereaddata/upload/Circular/circ22.pdf
36. Hague Conference on Private International Law, "Judgments Project," https://www.hcch.net/en/projects/legislative-projects/judgments
37. Law Society of Hong Kong, "Practice Note on the Recognition and Enforcement of Foreign Judgments," https://www.hklawsoc.org.hk/pub_e/news/pubnews20161206a.pdf