Reciprocal Recognition and Enforcement of Foreign Judgments in China: Promising Developments, Prospective Challenges and Proposed Solutions

Consistent developments since 2016 demonstrate that China is determined to depart from its traditional practice – rejecting reciprocity-based judgment recognition and enforcement. This is strongly endorsed by China’s ‘One Belt, One Road’ ( obor ) Initiative. To develop the Chinese system of reciprocity-based judgement recognition and enforcement ( jre ), China will make two efforts. First, it is likely to propose unbinding memos, like the China-Singapore Memo, to the supreme courts in countries alongside the obor . Second, Chinese Supreme People’s Court will issue a judicial interpretation to clarify the scope, requirements of, and defences against reciprocity-based jre .