lutzi

This book examines the EU Member States’ national rules on recognition and enforcement of Non-EU judgments.

Through its country report methodology, it explores the rules of 21 Member States in a structured manner. The emerging points of convergence - and divergence - form the basis of a detailed comparative report, which provides a unique overview of the current legal framework of recognition and enforcement of non-EU judgments across the European Union. This allows for (at least) three intriguing points of comparison: between the laws of the individual Member States; between the laws of the Member States and the legal framework applicable to EU judgments under the Brussels Ia Regulation; and between the laws of the Member States and the 2019 HCCH Judgments Convention.

This ambitious and unique work will be an indispensable reference for scholars, policymakers, and practitioners in the field of international commercial law.

Tobias Lutzi is Junior Professor for Private Law at the University of Augsburg, Germany.
Ennio Piovesani is a lawyer specialising in International Law registered with the Pistoia Bar Association, Italy.
Dora Zgrabljic Rotar is Associate Professor at the Chair of Private International Law at the University of Zagreb, Croatia.