Lloyd's Maritime and Commercial Law Quarterly
PRE-EMPTIVE RELIEF AGAINST FOREIGN JUDGMENTS OBTAINED BY FRAUD
Shaun Elijah Tan*
Mengiste v Endowment Fund for the Rehabilitation of Tigray
A. Introduction
It has oft been repeated that “fraud unravels everything”.1 So it seems, and an English court would not countenance any application for recognition or enforcement of a foreign judgment obtained by fraud. Mengiste v Endowment Fund for the Rehabilitation of
* I am grateful, as always, to Professor Adrian Briggs for his insightful and invaluable comments. I should also like to thank Ms Weiran Zhang for scrupulously, and meticulously, subjecting an earlier draft to scrutiny. All errors remain solely my own.
1. Lazarus Estates v Beasley [1956] 1 QB 702, 712, per Denning LJ.
Case and comment
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