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Ian Fletcher and the Internationalist Principle

As Ian Fletcher put it in his outstanding treatise on international insolvency: “The increased awareness in recent times of the negative consequences of [the] international fragmentation of policy and approach to cross-border insolvency issues has fueled the quest for improved solutions.” No one has contributed more to that goal. This paper discusses the difficulty created by the Rubin decision in which the English Supreme Court declined to enforce an American bankruptcy judgment for recovery of money. It proposes an approach that would distinguish reorganization judgments and permit them to be recognized. The theoretical basis would be the in rem nature of bankruptcy as to discharge as well as to title to property.