The Recognition and Enforcement of Punitive Damages Judgments Across the Globe

Thus far, private international law issues relating to punitive damages have mainly been dealt with from the perspective of several European countries. Systematic research into countries outside Europe was lacking up until now.

There is, however, a continuous discussion in various legal systems worldwide on the recognition and enforcement of foreign punitive damages judgments and, in particular, regarding their compatibility with the public policy of the country of enforcement. In October 2021, the Maastricht European Private Law Institute (M-EPLI) organised a Roundtable on the recognition and enforcement of punitive damages across the globe. Experts from different continents reflected on the current position in their jurisdiction(s) and exchanged their understandings and ideas in the Roundtable.

This resulting book includes an introductory chapter on the status quo of punitive damages enforcement in Europe, followed by country reports from Russia, China, South Korea, the Philippines and Japan, Commonwealth Africa, Mexico and Argentina, and Brazil. In conclusion, overarching insights from the Hague Conference are formulated. This book provides an invaluable resource for academics, judges, practitioners and policy makers in the field of private international law, punitive damages, and civil law remedies. It gives an overview of the treatment of punitive damages judgments across continents and may serve as a building block for further research.