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American courts (both Federal and State Courts) have no jurisdiction over Canadian residents or companies in Canada. In order for a US judgment or letter rogatory to have effect over a Canadian resident or company, an application must be made to the relevant Canadian court to approve the order.
A foreign judgment is recognised if it is conclusive, as provided in Section 13 of the Code of Civil Procedure. In Duggamma v Ganeshayya (AIR 1965 Kant 97), the Karnataka High Court held that the rule on the conclusiveness of a foreign judgment applies only to matters directly adjudicated upon.
Enforcement of a judgment issued by an out-of-state court, excluding judgments applicable to other rules such as child support or orders of protection, requires a copy of the foreign judgment to be filed in the office of the circuit clerk for any county in Illinois.
Enforcement cannot be accomplished by means of letters rogatory in the United States. Under U.S. law, an individual seeking to enforce a foreign judgment, decree or order in this country must file suit before a competent court. The court will determine whether to recognize and enforce the foreign judgment.
A suit for the foreign judgement should be filed within 3 years from the date of the judgment. In case of a foreign judgement not being recognised as conclusive, an enforcement suit cannot be initiated.
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The first step in enforcing a Quebec or foreign judgment in Ontario is to commence an action to enforce the judgment. Depending on the amount due, the action should be brought in either the Small Claims Court (amounts under $25,000), or the Superior Court of Justice.
Enforcement of a Foreign Judgment in the U.S. Under U.S. law, an individual seeking to enforce a foreign judgment, decree or order in this country must file suit before a competent court. The court will determine whether to recognize and enforce the foreign judgment.
To register a foreign judgment, one must file a new California lawsuit. If the California court recognizes the decision from the foreign court, it will issue an essentially identical judgment. Therefore, the California court does not have to rehash the substantive issues of the foreign lawsuit.
In the United States, foreign awards are typically subject to the Federal Arbitration Act (FAA) Chapter 2s limitations period of three years. See 9 U.S.C. 207. Tolling for this three-year limitations period is relatively limited.
To enforce a foreign judgment in India, the decree-holder must institute a suit for enforcement before an appropriate court. This procedure is insisted upon that any decision by a foreign court is not enforceable in a country unless such a decision is embodied in a decree of a court of that county.

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