Commercial Litigation
After obtaining a favourable judgment in a foreign country, one may wish to enforce the judgment in Israel. This is the case, for example, when the debtor has assets in Israel or when the successful litigant seeks to enforce compliance with the provisions of the judgment on an Israeli citizen or company. As in many other judicial systems, a judgment rendered by a foreign country is not automatically recognised in Israel and must undergo an ‘acceptance’ proceeding to gain legal status – whether for the purpose of being enforced, ie, being executed, or in order to be recognised.
Israeli jurisprudence on the enforcement (and recognition) of foreign judgments has developed over the years, on the basis of legislation, case laws, arrangements adopted from the English common law (which was the law of the land prior to the establishment of the State of Israel), and international conventions that Israel acceded to. As a result, a system of rules has been developed over the years that presents creditors in foreign judgments with a variety of courses of action.
