Absence of the State Immunity as a Prejudicial Fact Established by a Foreign Court Ruling

The article analyzes two judicial acts, in which two diametrically opposite approaches to determining the consequences of the conclusion contained in a foreign court decision on the absence of jurisdictional immunity of the state are applied. As a result, the outcome of the proceedings in the Court of Appeal of England in the case of Hulley Enterprises Ltd & Ors v The Russian Federation is prognosticated.