Court of Appeal refuses to allow cross-border ‘judgment laundering’ (Strategic Technologies v Procurement Bureau of the Republic of China)

Article summary

Dispute Resolution analysis: Addressing a novel point of law, the Court of Appeal has unanimously held that it is impermissible to register in England a judgment of a Commonwealth court which is itself derived from a judgment of another Commonwealth state. The court took a purposive approach to interpreting the Administration of Justice Act 1920 (AJA 1920) and concluded that to permit registration of a ‘judgment on a judgment’ would unbalance the principle of reciprocity that is central to that legislation. Here, the claimant obtained a judgment in Singapore, which it then sought to enforce by a common law action on the judgment in the Cayman Islands. The question before the Court of Appeal was whether it was permissible to register that Cayman judgment in England. By declining to do so, the Court of Appeal has put a stop to cross-border judgment laundering. Written by Kate Gee, senior associate, at Signature Litigation.