Appeal Judgment in the Registration and Enforcement of Foreign Judgments : Sidoli and anor v. Sidoli and anor [2026] EWHC 2769 (BP)
Sarah Egan successfully represented the Appellants in Sidoli and anor v. Sidoli and anor [2026] EWHC 2769 (BP), in which the High Court has found that foreign judgments dealing with a multiplicity of subject-matter including succession can be registered where the court has established which elements would be recognised as being registrable under English law.
The case concerned whether Italian succession judgments could be registered and enforced under The Foreign Judgments (Reciprocal Enforcement) Act 1933 (‘the 1933 Act’). The Court found that when determining whether foreign judgments can be registered under the 1933 Act it is necessary to characterise the subject-matter of those judgments. The Court concluded that where different elements of a foreign judgments to be registered fall to be dealt with in accordance with different rules of jurisdiction, then it may also be appropriate to break the judgment down to allow registration of the judgment to the extent that the English courts would recognise the matter as being properly within the jurisdiction of the foreign courts. The learned Judge found that at first instance the Court ought to have broken down the subject matter of Italian Judgments the Appellants were seeking to register to and the Court should have allowed the Italian Judgments to be registered insofar as they reflected that analysis.
The Judgment resolves the tension between the conflicting first instance decision of Sidoli v Sidoli [2025] EWHC 1425 (Ch) and the earlier decision of Del Curto v Del Curto [2023] EWHC 2106 (KB). The Judgment contains useful guidance on how to approach the registration and enforcement of foreign judgments under the 1933 Act in circumstances where the original proceedings underlying the judgment to be registered treat a multiplicity of subject-matter.
