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Non-Recognition of Foreign Judgments
"A court need [not] recognize a judgment of the court of a foreign state if the [c]ause of action on which judgment was based, or the judgment itself, is repugnant to the public policy of the United States or of the State where recognition is sought."

RESTATEMENT (THIRD) OF THE FOREIGN RELATIONS LAW OF THE UNITED STATES, §  482(d) (1986).

“A reservation incompatible with the object and purpose
of a treaty is [void] as a matter of International law
.”

Vienna Convention on Law of Treaties, Art. 19, 1155 U.N.T.S. 331.

HUMAN RIGHTS ACT OF 1988: 'ACTS OF ‘PUBLIC AUTHORITIES’':  
is an Act of Parliament of the United Kingdom Its aim is to "give further effect"
in UK law to the rights contained in the European Convention on Human Rights:

SECT 6.1: “It is [‘unlawful’] for a public authority to act in a way which is incompatible with a Convention right”;
SECT 7.1(b) “A person who [claims] that a public authority has acted (or proposes to act) in a way which is made unlawful by section 6(1) may
 - (a) bring proceedings against the authority under this Act in the appropriate court or tribunal
, 
[OR] rely on the Convention right (or rights) concerned ‘in [any] legal proceeding’.
* Even the UK will NOT recognize such Judgments
' UK Acts of Public Authorities'

Laws regarding the Non-recognition of Foreign Judgments that are obtained by fraud or made contrary to the basic rights of Due Process & 'Natural Justice,' specifically to ensure fair & impartial trials (and procedures),  are uniformally considered repugnant to public policy in any country.  This language is consistent throughout the United States, Canada and Europe under Foreign Relations Law, under the Human Rights Act 1988 ('ACTS OF PUBLIC AUTHORITIES') and pursuant to the Vienna Convention on the Law of Treaties.  See also the 'Foreign Judgment Enforcement Guide' for more details...

' Foreign Judgment Enforcement Guide

U.S. Chamber Institute for Legal Reform published a document on October 2011 on "Abusive Foreign Judgments" demonstrates why comity "requires  U.S. courts to deny recognition and enforcement to ANY  foreign judgment that violates the U.S. Constitution and other deeply rooted domestic principles."
' Abusive Foreign Judgments Paper'

WELL-ESTABLISHED LAW ON FRAUD
UNITED STATES

1.)   TEXAS SUPREME COURT held “foreign laws violate Texas public policy if they are inimical to good morals, natural justice, or the general interests of the States citizens.”  Gutierrez v Collins, 583 SW 2d 312, 322 (Tex 1979).

2.)   TEXAS CIVIL PRACTICE & REMEDIES CODE §36.005: 
 “(b) A foreign judgment is [not] conclusive if: the cause of action on which the judgment is based is repugnant to the public policy of this State.”

3.)   TX CIV PRACT & REM CODE § 35.003: 
 A foreign judgment is subject to same procedures, defenses & [p]roceedings for reopening, [vacating], staying, enforcing, or satisfying a judgment as a judgment of the court in which it is filed. 

4.)
TX FAMILY CODE §152.105(b)(c): THE UNIFORM CHILD CUSTODY JURISDICTION & ENFORCEMENT ACT (UCCJEA)
“A court of this State need [not] apply this Chapter if child custody law
of the ‘foreign’ country is [not] made under ‘FACTUAL CIRCUMSTANCES’ and in conformity with the UCCJEA or violates the fundamental principles of human rights.”

5.)
  TEXAS COURT OF APPEAL; 8TH DIST:
Velez v. Mitsak:  No. 
08-01-00246-CV:


Velez argued that 'blindly' awarding full-faith & credit to an Italian judgment caused the court to deny an evidentiary hearing on whether it should defer to the Italian judgment, alleging that it had been procurred by fraud. In her third and fourth points, Velez contended the trial court's failure to hear testimony on material issues that would illustrate the foreign judgment had been procurred by fraud, denied her Due Process of law under the United States Constitution and therefore constituted reversible error. 
                                                              - the Court of Appeal Agreed:

“Velez was entitled the opportunity to establish the defenses she had pled and to challenge the Italian judgment on the ground that it was procured by fraud.  It was surely not contemplated by the drafters of the Convention that the provision requiring contracting states to use the most expeditious procedures available to implement the objectives of the Convention would override a party's right to present evidence on possible defenses as provided in the articles or on considerations of whether a foreign judgment was obtained by fraud."
* Breach of Due Process
* Even the UK will NOT recognize such judgments
* Landmark Hague cases refused recognition
* How did this go so "BADLY WRONG?"
* PLEASE contact these people ASAP
              WE NEED YOUR VOICE

WELL-ESTABLISHED LAW ON FRAUD
UNITED KINGDOM

1.)  UK SUPREME COURT PRACTICE (1970), p.327, has this sentence: ‘If a judgment or order has been obtained by fraud or where evidence which could not possibly have been adduced at the original hearing is forthcoming, a fresh action will lie to impeach the original judgment.’”

2.)  PRACTICE DIRECTION OF THE SUPREME COURT: Para 1.2.8
"Civil cases that involve perverting the course of justice through fraud constitutes a civil contempt of court, and an appeal may be brought to the Supreme Court under Article 13 of the Administration of Justice Act 1960"...  "If after permission to Appeal is refused, an application for permission to Appeal may then be made to the (UK) Supreme Court."

NOTE: After the UK Court of Appeal  denied Bart "permission" to appeal, and  his plea to submit fresh evidence to prove the lower decision had been procurred by fraud, Bart pleaded with the judge for permission to appeal to the (UK) Supreme Court; the judge refused this request as well, citing:  "you have no right to do so."  
 
 
-  WE NEED YOUR VOICE

3.)  Giving leading judgment on Fraud in the UK Court of Appeal, Holroyd Pearce LJ said this at p379:  “Where a party deliberately misleads the court in a material matter, and that deception has probably tipped the scale in his favour (or even, as I think, where it may reasonably have done so), it would be wrong to allow him to retain the judgment as unfairly procured.  Finis litium is a desirable object, but it must not be sought by so great a sacrifice of justice which is and must remain the supreme object.  Moreover, to allow the victor to keep the spoils so unworthily obtained would be an encouragement to such behaviour, and do even greater harm than the multiplication of trials.”

4.)  SKONE V SKONE [1971] 1 WLR 812 the House of Lords (now the UK Supreme Court) allowed a husband's appeal and ordered the new trial following the discovery of fresh evidence; Lord Hodson said at p817:  “Assuming, as I think your Lordships must for the purposes of this application, that the letters sought to be tendered as evidence are genuine, the basis of the judge's finding of fact at the trial has been falsified to such an extent that to leave matters as they are would, in my opinion, be unjust."

5. ) House of Lords: BOODOOSINGH V RAMNARCE, Court of Appeal - Privy Council, March 08, 2005, [2005] UKPC 9;  Lord Brown of Eaton-under-Heywood cited at Para 18:
"There is no doubt that a judgment obtained by fraud can be set aside, either by order made in a fresh action brought in fraud, to impeach it, or on appeal to the Court of Appeal by adducing fresh evidence sufficient to establish the fraud." 
* UK Law on Hague Cases