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‘Judgments on judgments’ capable of registration under the Administration of Justice Act 1920 (Strategic Technologies v Procurement Bureau of the Republic of China Ministry of National Defence)

‘Judgments on judgments’ capable of registration under the Administration of Justice Act 1920 (Strategic Technologies v Procurement Bureau of the Republic of China Ministry of National Defence)
Published on: 05 March 2020
Published by: LexisPSL
  • ‘Judgments on judgments’ capable of registration under the Administration of Justice Act 1920 (Strategic Technologies v Procurement Bureau of the Republic of China Ministry of National Defence)
  • What are the practical implications of this case?
  • What was the background?
  • What did the court decide?
  • Was there valid service?
  • Should service be validated retrospectively?
  • Registration of a judgment on a judgment
  • Allowing late registration of a judgment
  • Case details

Article summary

Dispute Resolution analysis: This case confirms the importance of the formal steps relating to service outside of the jurisdiction. In particular, where such steps are not undertaken in accordance with the law of the country to which service is to be effected, enforcement steps taken are liable to be set aside as premature. It also confirms that the Administration of Justice Act 1920 (AJA 1920) is broad enough to allow the registration of judgments obtained without a consideration of the merits (ie judgments in default). As such, it is permissible to register a ‘judgment on a judgment’, as AJA 1920, s 12 is very broad and the word ‘any’, in particular, is powerfully inclusive. While there is an argument for deterring the ‘laundering’ of judgments, until parliament makes legislative change, such practices are acceptable. Written by Georgia Whiting, barrister, 4 King’s Bench Walk. or take a trial to read the full analysis.

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