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This article focuses on recognition. Recognition in California is governed by the Uniform Foreign Money-Judgments Recognition Act for actions filed before Jan. 1, 2008, and the Uniform Foreign-Country Money-Judgments Recogni- tion Act for actions filed on or after that date.
The Supreme Court of India in the case of Satya v Teja Singh interpreted section 13 to the effect that fraud as to the merits of the case may be ignored but fraud as to the jurisdiction of the foreign court delivering the judgment is a vital consideration in the recognition of the decree passed by that foreign court.
The defendant can challenge recognition and enforcement of a foreign judgement by objecting that the judgment falls within the exceptions set out in Section 13 of the Code of Civil Procedure.
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.
[1] The ULC has also promulgated a model law dealing with the enforcement of sister state judgments, entitled the Uniform Enforcement of Judgments Act (1964), which New York adopted as CPLR Article 54 in 1970.
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691.1173 Foreign judgment; filing; effect. A copy of a foreign judgment authenticated in ance with an act of congress or the laws of this state may be filed in the office of the clerk of the circuit court, the district court, or a municipal court of this state.
Domesticating Foreign Judgements Obtain an authenticated copy of the original foreign judgment. File an application of filing a foreign judgement with the court. Record the domesticated judgment in the Superior Court of the Arizona county in which the defendant resides.
A judgment in one state can be enforced in another state because decisions of a court in State A are given full faith and credit in State B under the United States Constitution and accompanying federal and state statutes.
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.
Enforceable. Only foreign money judgments are enforceable (Explanation 2 to section 44A, CPC). Foreign judgments in commercial matters must be final, conclusive and satisfy the conditions of section 13 of the CPC to be enforceable in India (see Question 1).

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