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Jie Huang: Interregional Recognition and Enforcement of Civil and Commercial Judgments, Oxford and Portland, OR: Hart Publishing, 2014, 352 pp. Hardcover £65/€84.50

Published online by Cambridge University Press:  29 May 2015

Tan Lee Cheng
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Abstract

Review of “Interregional Recognition and Enforcement of Civil and Commercial Judgments” by Professor Jie Huang (Oxford and Portland, Oregon: Hart Publishing, 2014) which analyses the status quo of judgment recognition and enforcement in the Mainland China, Macao and Hong Kong under the ‘One Country, Two Systems’ regime. The book also presents a comparative study of the interregional recognition and enforcement of judgments in the US and EU.

Keywords

judgment recognition and enforcementcomparative lawAsia
Type
Book Review
Information
Asian Journal of Comparative Law , Volume 9: Special Issue: Socio-Legal Research on Southeast Asia: Themes, Directions, and Challenges , 1 January 2014 , pp. 381 - 385
Copyright
Copyright © Faculty of Law, National University of Singapore 2014

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References

1 See for example German Zueblin International Co. Ltd v. Wuxi Walker General Engineering Rubber Co., Ltd (2006) Foreign-Related Commercial and Maritime Trial, edited by the 4th Civil Trial Division of the Supreme People’s Court, People’s Court Press, Issue 3, 2004, at 36-40, where the Court of Appeal of Berlin recognised a judgment issued by the People’s Court of Wuxi Province and also in Singapore, the case of Giant Light Metal Technology (Kunshan) Co. Ltd v. Aksa Far East Pte Ltd [2014] SGHC 16 where the Singapore High Court recognised a judgment obtained from the Suzhou Intermediate Court, Jiangsu Province.

2 Hubei Gezhouba Sanlian Indus. Co. v. Robinson Helicopter Co., No. 2:06-cv-01798-FMC-SSx, 2009 WL 2190187, (C.D. Cal. July 22, 2009), aff’d, 425 F. App’x 580 (9th Cir. 2011).

3 All of the jurisdictions mentioned above – US, Germany and Singapore – have not entered into any JRE bilateral treaty with Mainland China.

4 The Arrangement between the Mainland and Macao Special Administrative Region on Mutual Recognition and Enforcement of Civil and Commercial Judgments signed in 2008.

5 The Arrangement on Reciprocal Recognition and Enforcement of Judgments in Civil and Commercial Matters by the Courts of the Mainland and of the Hong Kong Special Administrative Region Pursuant to Choice of Court Agreements between Parties Concerned signed in 2006.

6 Huang explains that the word “Arrangement” is less formal than terms such as “agreement, convention or treaty” and is deliberately chosen as the word in Chinese “安排” has a stronger connotation of family and of reaching a consensus harmoniously and jointly.

7 [1996] 2 HKLR 395.