RECOGNITION AND ENFORCEMENT OF FOREIGN COURT DECISIONS IN FRANCE: FEATURES IN THE PRESENCE AND IN THE ABSENCE OF AN INTERNATIONAL TREATY WITH THE STATE OF JUDGMENT

The article is devoted to key aspects of the recognition and enforcement of foreign judgments in France. The author analyzes the features of this legal institution, arising both in the presence and in the absence of an international treaty with the state of judgment. The examples of international treaties with individual Asian countries cited in the article clearly demonstrate the heterogeneity of the French approaches to the content of these agreements from the point of view of the considered issues. The author's analysis of the domestic legislation of France in the enforcement of foreign court decisions confirms the significant role of jurisprudence in the procedure for obtaining exequatur. Special attention is paid to the perfection in the French legislation of the studied legal institution in connection with the entry into force of the new EU Regulation governing the recognition and enforcement of foreign judgments in the European Union, of which France is a member. Attracting attention by the author to the study of French approaches to the legislative regulation of the recognition and enforcement of foreign court decisions targets on the use of foreign experience in the interests of perfecting the Russian legislation in this area.

признание и исполнение иностранных судебных решений, международный договор, публичный порядок, экзекватура