Özet:

Confession in a foreign judicial judgment in front of the national judiciary can only be done through one of two systems, the regulation of filing a new lawsuit, this regulation does not recognize the judgment rendered by foreign country, unless a new lawsuit has been instituted for claim that stipulated the foreign judgment, and the regulation of execution order, by monitoring the foreign rule to be recognized, by verifying that certain conditions provided by national law in the foreign rule to be recognized , the way of review is to review foreign judgment objectively , by reviewing of the judgment whether the foreign judge has properly applied the legal rule to the dispute, Some countries do not recognize the foreign rule unless there is an international agreement to do so. The problem of the study revolves around the extent of the control of the national judiciary on the foreign right judicial judgment to be recognized before the national judiciary. The researchers used the descriptive analytical approach and the comparative approach as necessary, the researchers found a set of results and recommendations: There are two regulations for recognizing foreign rule: a new lawsuit and an enforcement order. The most important recommendations are to recognize foreign judgments unconditionally and to those affected by that objection, whether by questioning before the Execution Department or establishing a lawsuit before the competent court

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