FOREIGN JUDGMENTS IN QUEBEC
AbstractArticle 210 of the Quebec Civil Code of Procedure states the defences to an action in Quebec to declare a foreign action executory. This article traces the source of that provision in the old French law, indicates whether codification preserved or destroyed the old law, explains the reception of the old law in Quebec and reviews its application by the jurisprudence. Its purpose is to show that the Quebec doctrine has confused the intent of the common law principle codified in article 210, requiring the plaintiff to sue again on the merits, and that it has for practical purposes sanctified the English doctrine.
Keywords:Conflict of Laws
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