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Международный договор как правовое основание признания и исполнения иностранных судебных решений: прошлое, настоящее, будущее
The article provides a political and legal analysis of the provision establishing that treaty is a precondition for the recognition and enforcement of a foreign judgment. The author suggests that this statutory provision came into existence at the turn of the nineteenth century and its primary purpose was to ensure the equality of concessions between states in the field of justice. It is further noted that the reciprocity provision served the same purpose as the international treaty and that was the reason why it spread to legislations of several European countries (Germany, Romania etc.). As regards the Russian legal framework, the author discusses the correlation between existing national legislation and the right to fair trial under Art. 6 of the European Convention on Human Rights.