the Civil Procedure Code (CPC), foreign judgments can

encompass various types of judicial decisions or orders

arising from legal proceedings conducted in foreign
jurisdictions. These judgments may involve different
categories of disputes and can include the following types :

1. Monetary Judgments: These judgments involve the

award of a specific sum of money to one party by the
court, typically as compensation for damages, breach of
contract, or other financial obligations. Monetary
judgments may arise from civil litigation, commercial
disputes, or claims for restitution or compensation
2. Declaratory Judgments: Declaratory judgments are court
rulings that clarify or determine the legal rights,
obligations, or status of the parties without necessarily
awarding any specific remedy or relief. They are often
sought to resolve disputes concerning property rights,
contractual interpretation, or legal capacity, providing
certainty regarding the parties' legal relationship
3. Injunctive Relief: Foreign judgments may include orders
for injunctive relief, which prohibit or require certain
actions by the parties to prevent irreparable harm or
maintain the status quo pending further legal proceedings.
Injunctions may take various forms, such as temporary
restraining orders (TROs), preliminary injunctions, or
permanent injunctions, and can address issues like
trademark infringement, unfair competition, or breaches of
confidentiality.
 4. Orders for Specific Performance: In cases involving
contracts or agreements, foreign judgments may include
orders for specific performance, compelling a party to
fulfill its contractual obligations as agreed upon in the
contract. Specific performance is typically sought when
monetary damages are inadequate to remedy the breach
and when the subject matter of the contract is unique or
of special value.
5. Family Law Judgments: Foreign judgments may cover
various family law matters, including divorce decrees, child
custody determinations, spousal support orders, and
property settlements. These judgments address issues
related to marital dissolution, parental rights, and financial
arrangements between spouses or domestic partners.
6. Criminal Judgments: While the enforcement of foreign
criminal judgments may be subject to specific legal
requirements and considerations, certain types of criminal
judgments may also fall within the scope of the CPC. These
may include judgments related to extradition, mutual legal
assistance in criminal matters, or recognition of foreign
convictions for the purposes of sentencing enhancements
or parole eligibility.

 Legal principles governing foreign judgment

recognition-
The recognition of foreign judgments is governed by several
legal principles that aim to ensure fairness, respect for due
process, and consistency in international judicial cooperation.
These principles provide the framework for assessing the
validity and enforceability of foreign judgments within the
domestic legal system. Some of the key legal principles
governing foreign judgment recognition include

1. Comity: Comity is a foundational principle in international

law that emphasizes respect and deference to the judicial
decisions of other sovereign nations. Under the principle
of comity, domestic courts may recognize and enforce
foreign judgments out of courtesy and reciprocity, even in
the absence of binding legal obligations. Comity
encourages cooperation among nations and fosters
mutual respect for their respective legal systems
2. Finality: Foreign judgments seeking recognition and
enforcement must typically be final and conclusive in the
jurisdiction where they were rendered. Finality ensures that
the rights and obligations established by the foreign court
are settled and not subject to further review or
modification, thus providing a basis for their recognition
and enforcement in other jurisdictions.
3. Jurisdictional Competence: Recognition of foreign
judgments requires that the foreign court had
jurisdictional competence to hear and adjudicate the
dispute in accordance with the principles of international
law and due process. This includes considerations of
personal jurisdiction over the parties, subject matter
jurisdiction, and compliance with procedural requirements
for notice and opportunity to be heard.
4. Due Process and Fair Trial Rights: Foreign judgments
must be rendered in compliance with principles of due
process and fair trial rights guaranteed under international
law. This includes the right to a fair hearing, the right to
present evidence and arguments, and the right to be
heard by an impartial and independent tribunal.
Recognition may be denied if the foreign court's
procedures were fundamentally unfair or if there was a
denial of justice.
5. Consistency with Public Policy: Domestic courts may
refuse to recognize or enforce foreign judgments that are
contrary to the public policy of the forum state. Public
policy considerations may encompass fundamental
principles of justice, morality, or public welfare, and
recognition may be denied if enforcing the foreign
judgment would violate these principles.
6. Reciprocity: Some jurisdictions may require a showing of
reciprocity for the recognition and enforcement of foreign
judgments. Reciprocity ensures that judgments rendered
by the forum state's courts will be recognized and
enforced in the foreign jurisdiction on a similar basis. This
principle promotes fairness and equity in international
judicial cooperation.
7. Non-Extraterritoriality of Law: Domestic courts typically
apply the principle of non-extraterritoriality of law, which
means that they do not enforce foreign laws as such but
recognize and enforce the rights and obligations
established by the foreign judgment. This principle
ensures that recognition and enforcement are based on
the legal effects of the foreign judgment rather than the
substantive laws of the foreign jurisdiction.