The end of the Brexit Implementation Period on 1 January 2021 put an end to Brussels I (Recast)’s common system of jurisdiction and enforcement in civil and commercial matters (except for pending claims) as between the EU and the UK. We blogged about the Government’s guidance on the new status quo here.
Of particular concern for English claimants suing French defendants in the future is the question of how and when an English court’s judgment can be enforced in France. As we pointed out in a previous blog post, the question of possible enforcement must be addressed as a matter of priority by any cross-border practitioner considering new litigation.
We are grateful to Karel Roynette of Grenier Avocats for this eye-opening blog post setting out the difficulties that English claimants may now encounter despite having successfully pursued a French defendant to judgment.
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