Legal analysis reveals conflicting treatments of foreign court rulings on jurisdictional state immunity, highlighting divergent appellate outcomes in international disputes.
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.
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Nikolay G. Eliseev (2024) studied this question.
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