At common law, a foreign sovereign state and its head of state were entitled to claim immunity from the jurisdiction of the English courts in any action in which it was directly or indirectly impleaded. No distinction was drawn between actions which arose from the foreign state's official acts (acta jure imperii) and those which arose from its commercial activities (acta jure gestionis), as was the case under the law of many other states1. In 1972, the United Kingdom signed the European Convention on State Immunity2, which draws this
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