The public policy exception as grounds for refusing to recognize or enforce foreign court judgments in succession cases

Abstract The number of cross-border civil proceedings is on the rise and is likely to increase in the future. The above also applies to succession law regulating the statutory order of succession. Therefore, national courts adjudicating a succession case have to be familiar with and respect foreign laws indicated by the appropriate conflict-of-law rule. Significant problems may also arise when a succession judgment issued by a foreign court needs to be recognized or enforced by a national court. The relevant proceedings may violate the core values of the national legal system of the forum state. In this case, national courts are faced with a difficult choice between the need to respect the rule of international civil procedure, in particular the principle of mutual trust in foreign courts, and the need to recognize and apply national legal mechanisms that safeguard the principles and values fundamental to the domestic legal order.