چکیده:
With the transformation of political and economic systems, the world is becoming a global village, and its needs to harmonize laws and regulations and the globalization of rights is more and more concrete. In this study, the conditions and barriers to the recognition and enforcement of foreign judgments in Iranian law have been adapted to EU rules, and the implementation and differences of judgments in both systems have been investigated. The results showed that the commonality of both systems is that only civil and commercial sentences can be identified and enforced, and criminal and administrative and tax decisions are excepted. The study found that EU regulations could be shared between countries with regional and religious communities, such as the member states of the Islamic Conference, the Eco-Organization and the Non-Aligned Movement (NAM).
خلاصه ماشینی:
A Comparative Study of General Conditions for Recognition and Enforcement of Foreign Judgments in Iranian and European Union Law Mahmood Jalali 1*, Ali Norian 2 Abstract With the evolution of political and economic systems, the world is turning into a global village, and the need for harmonization of laws and regulations and globalization of law is becoming increasingly apparent.
Therefore, most countries strive to create a favorable environment for the execution of foreign judgments within their jurisdiction by approving laws and regulations consistent with globally accepted principles, and in addition to general regulations and amending their domestic laws, through the conclusion of bilateral or multilateral treaties, they provide the possibility of recognizing and enforcing foreign judicial judgments within their sovereignty.
In any case, although there are ideological differences between the member states of the European Union and the Islamic Republic of Iran in some religious and issues such as human rights, some substantive legal issues and judicial systems, and the European Union, as the birthplace of Western civilization, has always shown sensitivity to the standards and methods of its humanistic civilization, and on the other hand, the Islamic Republic of Iran, given its Islamic ideology, is in opposition to the secular and liberal Western ideology with Europe has a fundamental ideological difference, and however, these differences do not prevent that at least in terms of form, the progress of the European Union in the direction of unifying laws and especially in the subject of recognition and enforcement of foreign judgments can be used, because we have no obstacle to modeling in formal rules and regulations.
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