{'fraction_non_alphanumeric': 0.022953328232593728, 'fraction_numerical': 0.0, 'mean_word_length': 4.6869565217391305, 'pattern_counts': {'":': 0, '<': 0, '<?xml version=': 0, '>': 0, 'https://': 0, 'lorem ipsum': 0, 'www.': 0, 'xml': 0}, 'pii_count': 0, 'substrings_counts': 0, 'word_list_counts': {'cursed_substrings.json': 0, 'profanity_word_list.json': 0, 'sexual_word_list.json': 0, 'zh_pornsignals.json': 0}}
Policies Underlying the Enforcement of Foreign Commercial Judgments

There is a tendency to divide legal development into historical stages, to say how wrong and befuddled we were in the past and to describe how we came finally to see the light. This inclination is particularly evident in the area of enforcement of judgments given by courts of foreign countries (in this article the term “foreign judgments” is confined to such judgments). Before the turn of this century, the main bases for enforcement were the concept of “comity” and the doctrine of “sovereignty”. These were criticised by later generations of lawyers who were uncomfortable with the vagueness of the terms and who could not agree on what they meant and how they should be used. In modern times positivist bases have been substituted in their place. So we had the “vested rights” theory, which did not last long as it was soon overshadowed by the “obligation” rationalisation. Most writers accept and, in their account of the theory of the law in this area, do not attempt to go beyond these words of Blackburn J: “The judgment of a court of competent jurisdiction over the defendant imposes a duty or obligation on him to pay the sum for which judgment is given, which the courts in [the country of enforcement] are bound to enforce.”