Recognition and Enforcement of Judgments in Commercial Matters Rendered by Courts of Non-EU Countries in the Czech Republic
Abstract
The paper presents an overall analysis of the conditions for enforcement of judgments rendered in commercial matters by courts outside of the European Union in the territory of the Czech Republic. The conditions under which the Czech Republic recognises the authority and attaches effects to foreign judgments in commercial matters vary depending on the judgment's country of origin, they vary depending on whether the foreign judgment in commercial matters is enforced based on EU law, international treaty or Czech national rules.
Czech national rules of private international law allow recognition and enforcement of judgments in commercial matters rendered by courts of states which are neither members of the EU (nor EFTA), nor parties to a binding multilateral or bilateral treaty that contains rules on recognition and enforcement of judgments in commercial matters. But the predictability of such a recognition or enforcement is quite limited given the requirements set by the Czech Private International Law Act.