Jurisdiction Under Private International Law.pdf

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1. Running head: ASSIGNMENT ON FOREIGN JUDGEMENT AND JURISDICTION UNDER
PRIVATE INTERNATIONAL LAW 1
Assignment on Foreign Judgement and Jurisdiction Under Private International Law
Aliba Jannat
2124057001
Md. Mazharul Islam
2124057002
Jakaria Ahmed
2124057003
M. Abir
2124057004
1
st
Semester
Department of Law
Leading University, Sylhet



Private International Law
LL. M-903
Shah Md. Omer Faruqe Jubaer
Senior Lecturer
Department of Law
Leading University, Sylhet
2
nd
October , 2021

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Abstract
When a case is brought before a court in any forum court, the first question is whether that court
has the power to hear the case. Such power is called jurisdiction. Rules of jurisdiction vary from
country to country which makes it complicated while dealing with a controversy or dispute in
which more than one country have interest to adjudicate. For example, suppose a plaintiff (P)
suffers personal injury in country A due to defendant’s (D) negligent driving who is a citizen of
country B. In this example, P would choose country A’s courts to bring his lawsuit against D, as
the incident happened there. On other hand, D will prefer the courts in his country of residence,
country B. Whether P or D will succeed on their claim for jurisdiction depends on rules of
jurisdiction in country A and B.
Keywords: adjudicate, dispute, jurisdiction, interest

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Assignment on Foreign Judgement and Jurisdiction Under Private International Law

Introduction
In this era of globalisation, Private International Laws have become a necessity. The need
for Private International Laws arises when there is a foreign geographical connection with the case,
or there is some presence of the foreign element. This foreign element can be anything ranging
from a contract between two parties of a different nationality to a tort committed with foreign
influence. In such cases, the concept of Private International Laws is also called ‘Conflict of Laws’.
In such cases, the court undertaking the case has to apply the principles of private international
laws along with the domestic laws. Almost all the nations have well-codified laws and a system of
conflict of laws. For understanding, let us see this way that the world is divided into different
territorial units, with each unit being governed by its specific laws considering contracts, sales of
goods, torts, etc. A person who belongs to one such territorial unit may travel to another unit and
get engaged in the contract. When he comes back and an issue regarding contract arises, then the
court with jurisdiction has to apply international private laws along with domestic laws.
Keywords: concept, conflict, contract, principles

Jurisdiction Under Private International Law
Jurisdiction means power of a court to adjudicate cases and issue orders. the first question
in an international case potentially involving conflict-of-laws problems is which court has
jurisdiction to adjudicate the matter. Although the plaintiff decides where to sue, the courts in that
location may not have jurisdiction, or they may have jurisdiction but be unwilling to exercise it,

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for reasons of forum non conveniens (Latin: “inconvenient forum”), as may happen in some
common-law countries.

Keyword: potentially, sue, unwilling

Concept of Jurisdiction Under Private International Law
In public international law, the concept of jurisdiction has traditionally had a strong link
with the notion of sovereignty. Jurisdiction allows States to give effect to the sovereign
independence which they are endowed with in a global system of formally equal States, through
stating what the law is relating to persons or activities in which they have a legal interest.
Sovereignty however not only serves as an enabling concept with respect to the exercise of
jurisdiction, but also as a restraining device: it informs the adoption of international rules
restricting the exercise of State jurisdiction. States may indeed well adopt laws that govern matters
that are not exclusively of domestic concern, and thereby impinge on other States’ sovereignty. In
essence, the laws of jurisdiction delimit the competences between States,1 and thus serve as the
basic ‘traffic rules’ of the international legal order.
Keywords: global, respect, exercise, notion, sovereignty

Rationale Behind Choice of Jurisdiction
There are several factors that affect the plaintiff’s decision of where to file a case. One is
convenience. For example, a plaintiff is likely to want to sue in a jurisdiction that is reasonably
close to his home, particularly because witnesses and evidence may be more readily available there.
Legal questions also are important. A plaintiff may be more likely to file suit in a jurisdiction that

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will afford him procedural and other advantages and where the defendant has assets with which to
satisfy an ultimate judgment. Examples of likely procedural or substantive law advantages include
the possibility of a jury determination of damages in a tort case, the availability of punitive
damages, the ease of obtaining pretrial discovery of evidence (commonly used in the United
States), the possibility of suing on only a part of one’s claim to determine the likelihood of success
before committing resources to a suit on the entire claim (a common practice in Germany), and
advantageous exploitation of variations in liability standards.
However, the place of suit is not entirely up to the plaintiff. The chosen court must have
the power to entertain the case (jurisdiction to adjudicate). The jurisdictional grant will usually be
defined by statute. In addition, the exercise of jurisdiction may also be limited (as a check on the
statutory grant or on the judicial exercise of it) by constitutional provisions or pervasive principles
of law. In addition, in common-law countries, provisions of law or court decision-making practice
may limit the exercise of jurisdiction to adjudicate for any number of reasons, including the need
to prevent local courts from becoming clogged with litigation with which they have no concern
(e.g., litigation between foreigners concerning a claim that arose abroad), especially when it seems
likely that the courts of the forum state were chosen only as a means of gaining procedural- or
substantive-law advantages not available to the plaintiff in his home country’s courts (so-called
“forum shopping”). C
Most countries allow the parties to agree to the jurisdiction of a court. Consent may take
the form of an express agreement in the initial business contract or at the time the dispute arises.
Alternatively, consent may be the result of conduct. The plaintiff’s consent appears from the filing
of the action. The defendant’s consent may be presumed when, rather than objecting to the court’s
jurisdiction, the defendant confesses judgment or appears and begins to litigate the controversy.

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Even when both parties consent to a court’s jurisdiction, the court in a common-law country may
still decline to hear the case—for example, when neither of the parties nor the controversy has a
connection to the country in which the court is located. In most cases, however, a court’s
jurisdiction is not an issue unless and until the defendant objects to it.

Keywords: litigation, consent, determination, evidence, action
Differences Between Civil-law and Common-Law Countries in the Absence of
a Choice by the Parties
Traditionally, civil-law and common-law countries have followed different approaches in
determining which court has jurisdiction in a civil action when the parties have not agreed on or
submitted to the forum. Civil-law countries start from the premise that there is one principal place
where a suit can be filed: the domicile of an individual or the seat of legal persons such as a
corporation (“general jurisdiction”). In addition to these general bases of jurisdiction, a suit
ordinarily may be brought in the courts of the place to which the suit has a special connection—
e.g., where a tort was committed or where its effects were felt, where the alleged breach of a
contract occurred, or, if title to real property is involved, where the property is located (“specific
jurisdiction”). Increasingly, countries have limited the exercise of jurisdiction (and have prohibited
parties from varying these limitations by agreement) for the protection of weaker parties, such as
employees and consumers. Such a pattern has emerged, for example, in the procedural law of the
EU.
Most countries provide some bases of jurisdiction for the benefit of local plaintiffs. French
law, for example, grants jurisdiction if the plaintiff possesses French nationality, and German
statutory law permits a local plaintiff to sue an absent defendant on the basis of any property the

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defendant may have in Germany, regardless of whether the litigation is related to the property or
even to Germany in any other way (though modern German court decisions have given provision
a more limited reach). Rules such as these, which favour plaintiffs (“transient jurisdiction” also
falls into this category), are known as “exorbitant” rules of jurisdiction. Within the EU they have
been abrogated in cases in which the defendant is habitually resident within the EU. However, EU
member-states may retain exorbitant jurisdictional bases of national law in cases involving non-
EU defendants. Internationally—i.e., beyond the EU—these rules, as well as the American “doing
business” jurisdictional rule, are a source of considerable tension. The Hague Conference on
Private International Law sought to formulate an international convention on jurisdiction and
judgment recognition. The effort was abandoned when the differences proved too large to bridge.
Instead, a much more limited convention on choice of court agreements was adopted in 2005 and
proposed for adoption by member states and others.
Both civil-law and common-law countries have special rules governing suits
for judgments in rem (Latin: “with respect to the thing”), which concern proprietary legal rights.
Unlike actions for judgments in personam (Latin: “with respect to the person”), which concern
personal legal rights and may seek money damages or injunctions to do or not to do an act, an in
rem action seeks a judgment that produces effects of its own on a legal relationship. Examples
include actions to quiet title to land, to foreclose a mortgage on land (by selling it), and to remove
a party’s interest that encumbers title to land. In common-law countries, family-status actions
(e.g., divorce or the creation of an adoptive family-child relationship) have been likened to in rem
actions; for example, in divorce proceedings, particularly in the United States, the domicile of each
spouse localizes the status and permits the court at the domicile to assert divorce jurisdiction. At
the same time, residence of varying length (from several weeks to several months) may take the

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place of—or may presumptively equal—domicile for divorce-jurisdiction purposes. In contrast,
civil-law countries have not likened divorce jurisdiction to in rem proceedings. They provide for
divorce, including the possibility of ex parte divorce (i.e., only the petitioner is before the court),
on the basis of a close relationship to the forum state—e.g., residence of a specified length of time.
Central to the continued divergence of these jurisdictional approaches is the applicable law: a court
following an in rem approach to status matters will always apply its own law. In contrast, courts
in civil-law countries treat the action as in personam and make a choice-of-law determination that
focuses on personal connecting factors such as the nationality or marital residence of the parties.
Because civil-law courts make choice-of-law decisions with reference to the particular parties and
their case, jurisdictional standards can be more liberal in those countries than in common-law
countries, where less-restrictive standards would lead to forum shopping.
Keywords: approaches, forum, contrast, divergence, domicile, residence

Notification to the Parties
Fundamental fairness requires that the defendant receive notice sufficient to afford him an
opportunity to defend. In common-law countries this notice is effected by “service of process” on
the defendant; similar procedures exist in civil-law countries. Service on the defendant in person
is considered ideal; alternatively, “substituted service” (e.g., even by publication) is a last resort
when the whereabouts of the defendant are unknown. International cases pose special problems.
Countries often cooperate bilaterally, either on the basis of express agreements or as a matter of
practice, in aiding each other’s courts to effect service on the defendant. A very effective
multilateral mechanism is the Hague Convention on the Service Abroad of Judicial and
Extrajudicial Documents in Civil or Commercial Matters, to which some 50 countries, including

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the United States, China, Russia, and all the EU states, are party. It provides for a “Central
Authority” in each member state that receives service requests from other convention states and
executes them according to its own national procedures.
Keywords: fundamental, Hague Convention, bilaterally, opportunity, agreements

Choice of Law
In its choice of the applicable law, the court that exercises jurisdiction determines which
law to apply to a case that involves foreign parties, foreign transactions, or a number of foreign
elements. In a simple world, the court would always apply its own law, the law of the forum (known
in Latin as the lex fori). Indeed, some modern methodologies, particularly in the United States,
favour the lex fori approach.
Keywords: foreign, transaction

Traditional Rules
 Lex Loci Celebrationis
This rule governs the formal validity of the marriage, the meaning of lex loci celebrationis is ‘Law
of the place where the marriage takes place’.
 Lex Domicili
Lex Domicili governs the capacity and validity of the marriage of two parties. Lex domicili, which
means the law of the domicile, at the time of death of a person also helps in the succession of
movable property.
 Lex Situs

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Lex situs help in governing the matters related to the transfer of movable property. Lex situs which
means the law of the place, not only helps in the succession of the movable property but also helps
in transfer of immovable property.
 Lex Fori
Lex Fori or Law of forum helps in the governance of the law of procedure.
 Lex Loci Deliciti
As the name suggests it means the law of the place where the damage occurred, this rule concerns
the commission of a tort. This is one of the important traditional rules.
 Proper Law of Contract
Contractibility or say the contracts between different parties regarding different issues are
concerned with applicable law also called proper law of contract.
Recognition and Enforcement of Foreign Judgements

Foreign Judgement
A foreign Court is defined as a court situate outside the State and not established or continued by
the authority of the Government. And a Foreign Judgment means a judgment of a foreign court. In
other words, a foreign judgment means adjudication by a foreign court upon a matter before it.
Thus judgments delivered by courts in England, France, Germany, USA, etc. are foreign judgments.
Enforcement of Foreign Judgement
A foreign judgment, which is conclusive under Section 13 of the Code, can be enforced in India in
the following ways:
Keywords:
 By instituting a suit on such foreign judgment

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A foreign judgment may be enforced by instituting a suit on such foreign judgment. The general
principle of law is that any decision by a foreign court, tribunal or quasi-judicial authority is not
enforceable in a country unless such decision is embodied in a decree of a court of that country. In
such a suit, the court cannot go into the merits of the original claim and it shall be conclusive as to
any mater thereby directly adjudicated upon between the same parties. Such a suit must be filed
within a period of three years from the date of the judgment.
 Execution Proceedings
A foreign judgment may also be enforced by proceedings in execution in certain specified cases
mentioned in Section 44-A of the Code. The said section provides that where a certified copy of a
decree if any of the superior courts of any reciprocating territory has been filed in a District Court,
the decree may be executed in India as if it had been passed by the District Court. When a foreign
judgment is sought to be executed under Section 44-A, it will be open to the judgment-debtor to
rake all objections, which would have been open to him under Section 13 if a suit had been filed
on such judgment. The fact that out of six exceptions there has been due compliance with some of
the exceptions is of no avail. The decree can be executed under Section 44-A only if all the
conditions of Section 13 (a) to (f) are satisfied.
 Foreign Awards
Principles laid down in the section do not apply- It is not open to the party, who is party to the
award, to contend that the award was not given on merits of the case. Say that if the award was
given against the rules of natural justice or it was fraudulently obtained, the party may not be
prevented from putting forward those contentions. But it is difficult to accept the view that because
on a foreign judgment it is open to a party to contend that it was not given on the merits of the
case, it is equally open to a party who is resisting the suit on the award to contend that the award

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was not given on the merits of the case.
Only if the award given in a foreign country is reinforced by a decree of the Court of that country
the courts will be bound to take notice of it but without such a decree reinforcing such award, the
award must be deemed to be non-existent.
Keywords:
Leading Case Analysis of Private International Law
Krombach v Bamberski (Case for public policy)
The court of the Member State in which enforcement of the judgment was required in this
case civil compensation ordered by the Paris Assizes, could not take account in relation to the
‘public policy clause’ of the fact that the court from which the judgment originated based its
jurisdiction on the nationality of the victim of the relevant offence.
The court which sought enforcement could not, with respect to a defendant domiciled in the same
State and prosecuted for an intentional offence, take account under the ‘public policy clause’ of
the fact that the originating court refused to allow the defendant presentation of his defence unless
he appeared in person.
Interdesco SA v Nullfire Ltd (Case for fraud )
This cases give us general opinion about Foreign judgment; allegation of fraud; registration
of judgment in England; stay of English proceedings sought in France; whether appeal an
“ordinary appeal”
Nullfire appealed against an order that a foreign judgment obtained by Interdesco against Nullfire
should be registered in the High Court. Interdesco had been ordered, by the French Cour d’ Appel,
to pay damages to Interdesco for wrongful termination of an exclusive distribution agreement.
Nullfire argued that, as the judgment had been obtained by fraud, its recognition would be contrary

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to public policy under the ‘Convention on Enforcement of Judgments and jurisdiction in Civil and
Commercial Matters 1968 Art.27’. Nullfire had instituted a special appellate procedure in France,
“recours en revision” alleging fraud.
Appeal was dismissed in this case. The court could not apply the decision in Abouloff v
Oppenheimer & Co (1882-83) L.R. 10 Q.B.D. 259 whereby a debtor could challenge a foreign
judgment if there was fraud, because of the terms of Arts.29 and 34 of the Convention which
precluded review of the substance of foreign judgments. However, if the defendant wished to bring
a fresh action or provide fresh evidence the court might hear the case as long as there was no
remedy available in the foreign jurisdiction, Owens Bank v Bracco Financial Times, April 12, 1991.
In this case, Nullfire had a remedy in the recours en revision procedure which could take place at
any time. This procedure was not an ordinary appeal and therefore stay of proceedings in terms of
Art.30 was inappropriate.
Abouloff v Oppenheimer & Co
Where Lord Coleridge CJ said: “where a judgment has been obtained by the fraud of a
party to a suit in a foreign country, he cannot prevent the question of fraud from being litigated in
the courts of this country, when he seeks to enforce the judgment so obtained. The justice of that
proportion is obvious; if it were not so, we should have to disregard a well established rule of law
that no man shall take advantage of his own wrong”
This principle was reaffirmed by the House of Lords in Owens bank ltd V Bracco the claimant
bank claimed to have lent nine million Swiss francs to the defendant, who received the money in
cash against signed documents typed on the note paper of Geneva hotel. Braco resisted a claim in
the courts of Saint Vincent for the capital lent and interest, denying that he had ever entered into
the transaction. The bank succeeded, and sought to register the judgment in England under the

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administration of justice act 1920, to be met by an argument based on the banks alleged fraud in
making the claim.

The Role of Foreign Judgements to Enrich Domestic Legal Regime
In general, the sources of law are initially either 'formal source of law' or 'material source
of law', one from which a rule of law originates and derives its validity, force and authority and
the other from which the same (law) derives the subject matter or content, respectively. As a matter
of fact, the formal source of law varies with the sentiment and attitude of a particular community
which they believe and conceive i.e., if law is regarded as being created by the will of the state,
that is the formal source of law. Again, if law is command of the sovereign, such sovereign is the
formal source. On the other hand, material source of law, includes sources that generate, enact or
make rules/laws, of which, there exist two different streams of sources, namely legal material
source and historical material source. These two streams of material sources are distinctive in their
constituent elements, degree of legal authority or for that matter their persuasive instinct too.
The organs or instruments of a sovereign state (i.e., legislature, custom and authority of the
President to promulgate Ordinance under article 93 of the Bangladesh Constitution) through which
legal rules/laws are being created and known are legal material source. They are not only
authoritative but also, as a matter of norms, accepted and followed by all courts of law within the
territorial jurisdiction of that particular state. However, the other material source of law (known as
historical material source) are unauthoritative in nature and initially not allowed by any courts of
law 'as of right', though subsequently may turn into law, if and when the same be argued and put
forward before a court to be accepted and thus when accepted, assumed the status of

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precedent/case-law. Common examples are 'foreign judgments', but sometimes even views and
opinions of jurist and authoritative textbook writers also come within this group.
Across different countries of the world, lawyers, while making their submission/arguments before
a court often place foreign judgments and decisions in support of their submission/arguments, to
convince them thereby not only facilitating entry, integration and acclimatisation of decisions in
the realm of legal domain in pursuit of justice, equity and good conscience, but also as a gateway
to grant their admittance. This is how advanced and modern version of legal interpretations and
findings spread around the world at large and thus, wisdom and erudition of judges and legal
luminaries enrich the legal domain.
Looking back, soon after our independence till date, an array of foreign
judgements/decisions has been cited by legal counsels of Bangladesh before the higher judiciary
and their Lordships upheld and accepted them as just and equitable. In Mrs. Aruna Sen v Govt. of
Bangladesh (1975) 27 DLR (HCD) 122, his Lordship D. C. Bhattacharya J., by taking into
consideration the English decision of Liversidge v Anderson (1942) AC 206, upheld the view
taken by Lord Atkins that "…every imprisonment without trial and conviction is prima facie
unlawful…" in cases of preventive detention by executive authority. Taking into consideration the
decision of Radul Shak v State of Bihar and another (1983) AIR (SC) 1086 in the Bilkis Akhter
Hossain v Bangladesh and others (1997) 17 BLD (HCD) 395 a claim under public law for
compensation in case of infringement of human/fundamental rights and freedom was recognised.
There are few noteworthy pronouncements of judgments by the Supreme Court of Bangladesh
under constitutional jurisdiction too, like that of – Dr. Mohiuddin Farooque v Bangladesh (1997)
17 BLD (AD), Muhammed Taiyeb v Government of Bangladesh (2015) 23 BLT (AD) 10, Shah
Abdul Hannan and others v Bangladesh [Writ Petition no. 3507/1998], Maulana Md. Abdul

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Hakim v Bangladesh (2015) 67 DLR 83, Children Charity Bangladesh Foundation v Bangladesh
and others (2017) 5 CLR (HCD) and Bangladesh National Women Lawyers Association
(BNWLA) v Bangladesh and others (2009) 29 BLD (HCD) 415.
Again in the cases of Dine Ara Begum and others v Bangladesh Rubber Industries and
others [Civil Appeal no. 1 of 2010], Maksudur Rahman and others v Bashati Property
Development Limited and others [Company Matter no. 17 of 1995] and in Hussain Mohammad
Ershad v Bangladesh and others (2000) 29 CLC (AD) on the question of application of
international obligations of sovereign states on international conventions and treaties respectively
were placed before the higher judiciary and were accepted.
In the above mentioned cases, our judiciary was gracious enough in allowing noteworthy
decisions of other jurisdictions to get admittance or entry into the legal regime of Bangladesh and
be considered as settled principle of law for future generation to cherish and admire the legal worth
of such timeless landmark judicial pronouncements. This is how the historical material source of
law enriches the domain of legal jurisprudence in our country and the world at large.

Conclusion
Jurisdiction, literally (the power of) saying what the law is, is at the same time the most
important and the most complex area of private international law. The complexities begin with
terminology. Jurisdiction, in common law parlour, encompasses two meanings that are at least
partly distinct in principle, even if they sometimes overlap in practice. These terminological and
conceptual differences mar many comparative law analyses; they also make it difficult to develop
a general theory. In one way, jurisdiction describes the outer limits of an institution’s reach. In this
sense, the concept is not confined to adjudication but applies to the activities of all three branches

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of government and beyond. Besides jurisdiction to adjudicate there is also jurisdiction to prescribe
and jurisdiction to enforce, which limit, respectively, the spaces in which a country can legislate
and enforce its own laws and decisions. The terminological differences show that, for purposes of
theory and comparison, a functional definition is necessary. Functionally, for purposes of private
international law, the law of jurisdiction can be defined as those rules and principles that determine
the circumstances under which a court is entitled to adjudicate and render a substantive judgment
with regard to the international and/or interstate connections involved.

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References

Kiestra, L. R. (n.d.). Jurisdiction in Private International Law. SpringerLink. Retrieved
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Conflict of laws - Applications in the United States. (n.d.). Encyclopedia Britannica. Retrieved
September 28, 2021, from https://www.britannica.com/topic/conflict-of-
laws/Applications-in-the-United-States#ref276365
All Answers Ltd. (2021, August 26). Enforcement of a Foreign Judgment. Law Teacher.
https://www.lawteacher.net/free-law-essays/commercial-law/enforcement-of-a-foreign-
judgment-commercial-law-essay.php
legal Service India. (n.d.). Legality of Foreign Judgments. Legality of Foreign Judgments.
Retrieved September 28, 2021, from http://www.legalservicesindia.com/articles/fore.htm

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