Research On The Recognition And Enforcement Of Judgment Of Foreign Punitive Damages

Punitive damages are the special product of damages system of common law system, however there are always dispute related to its conformity and justice. At present, how to recognize and enforce a foreign judgment which awards exemplary or punitive damages is a problem that needs to be solved by every country. This article focuses on this particular problem from three aspects. The first aspect is to reflect how to recognize and enforce a punitive damages judgment in those countries which belong to common law system. The secondary aspect is to focus on how other countries with civil law system deal with the issue. The third aspect sets forth how to settle this problem by Hague Conference on Private International Law. Finally, based on the forgoing analysis, a number of awareness and suggestions have been made specifically for our country in the recognition and enforcement of punitive damages judgment, and also it provides important references to be consulted while dealing with this issue in our country.