ABSTRACT
This article examines whether the common law recognises a category of foreign judgments ‘in matters of’ succession. Its argument is that it does not: the relevant question of characterisation is whether the orders contained in the foreign judgment are in rem or in personam. Where a foreign ‘succession’ judgment is partly in rem and partly in personam, the starting point is to treat each order separately. However, a foreign court having jurisdiction in personam is properly regarded as competent to make a determination in rem that forms a necessary basis for the order in personam. This analysis helps to resolve the uncertainty arising from the conflicting decisions in Del Curto v Del Curto and Sidoli v Sidoli.
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Andreas Giannakopoulos, The recognition of foreign succession judgments at common law, Trusts & Trustees. Published: 8 June 2026.
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