I Introduction

In an increasingly interconnected global economy, businesses engage in cross-border transactions that often give rise to disputes requiring resolution through different means including litigation. However, navigating the complexities of international commercial litigation, particularly in terms of the recognition and enforcement of judgments across borders, has been a longstanding challenge. When disputes arise, obtaining a judgment in one jurisdiction may not suffice if enforcement is necessary in another jurisdiction. The process of recognition and enforcement of judgments across borders presents complex challenges, ranging from differences in legal systems to issues of sovereignty and enforcement mechanisms. Divergences in service of process, evidence rules, and limitation periods can hinder the enforcement process and create opportunities for strategic manoeuvring by parties seeking to put off enforcement.