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Features of Recognition and Enforcement of Foreign Judgements in the Territory of the Russian Federation
The main problem of the execution of decisions of foreign courts is that the court
decision initially differs in the strictly territorial nature of its action, that is, it has
legal force only within the State where it was issued.320
The development of foreign economic relations, as well as the active movement
of citizens between States, give rise to litigation in which the interests of
Russian and foreign persons collide. Disputes arising from contracts, divorce,
adoption, establishment of paternity – this is a far from complete list of cases
that are annually considered by foreign courts.
Judicial decisions in the Russian Federation have territorial force. Judgment
is part of the legal order of the State in whose jurisdiction it was made. It is permissible
to recognise and enforce the decisions of national courts in other States
in cases stipulated by the legislation of these States or international agreements.