Ph.d student of Private Law at Arak Branch of islamic Azad University
Abstract
Today, due to advances in growing human societies and their inevitable dependence on each other, execution of judgments issued in other countries, is inescapable. There are two systems in foreign execution of judgments: 1) The French System or the principle of unenforceability of foreign judgments 2) The English- American System or the principle of enforceability of the foreign judgments which the later has been founded on the basis of the theories of civility, commitments, and the acquired rights. Iran and Lebanon’s legal system believes in the execution of foreign judgments under authoritative interpreter conditions and in the process of implementation of these provisions, the recognition and execution are considered as two separate issues. With scrutiny in these two countries it is noted that the recognition and enforcement is crucial and the judge of the Lebanese court powerfully enters this stage. As he accepts the restoration of justice to the issued verdict and sometimes suggests the third party's entrance in the process of trial and respects the correspondence principle as far as the execution of judgment in absence with the assumption of not absolutely notifying the defendant, has no position. With the assumption of validation of the foreign judgment, more time has been assigned for the defendant for objection to the issued judgment. As if once again the claim is being considered.
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