The international impact of the ruling with a view to the jurisprudence of Iran and Britain

Document Type : Original Article

Authors

1 Department of Law, Arak Branch, Islamic Azad University, Arak, Iran.

2 Assistant Professor of Law, Arak Branch, Islamic Azad University, Arak, Iran.

3 Professor 1- Law Department, Arak Branch, Islamic Azad University, Arak, Iran. 2- Law Department, Tehran Branch, Islamic Azad University, Tehran, Iran.

Abstract

The purpose of this study is the international effect of the sentence with a view to the jurisprudence of Iran and Britain. It has been done in a descriptive-comparative method. Maximum implementation of legal rulings issued by other countries is a requirement of modern life in the international arena. By accepting the general theory of the international impact of the sentence, the Iranian legal system has made it possible to execute criminal sentences issued by other countries. The jurisprudence of Iranian courts is such that by being less strict than the provisions of the Civil Judgments Enforcement Law regarding the enforcement of foreign judgments and the interpretation of the law in favor of the recognition and enforcement of foreign judgments, it has provided a good basis for international influence. In the United Kingdom, the existence of multiple legal systems for the enforcement of foreign judgments has been to facilitate the enforcement of foreign judgments in this country. In the meantime, the rules of the European Union provide better conditions for the enforcement of foreign judgments than the rules of the Commonwealth and the Law of Justice of 1920 and the Law of Reciprocity of 1933. In addition, the rules of the Commonwealth concerning the international influence of law, which are derived from the rule of precedent, are in line with the general theory of the international influence of judgment.

Keywords