Under the principle of , nations generally respect the judicial acts of others, provided the original court had proper jurisdiction and the proceedings were fair (not contrary to "public policy"). Without this mutual recognition, international trade would be paralyzed by legal uncertainty. The Core Tension: Sovereignty vs. Justice
Modern approaches have shifted toward the doctrine, which seeks the legal system with the most "significant relationship" to the transaction and the parties. 3. Recognition and Enforcement: Is the win valid elsewhere? The Conflict of Laws
The Conflict of Laws exists because the world is divided into independent sovereign states, each with its own legal rules. If every country’s law ended strictly at its borders, international life would be impossible. However, if one country ignores its own laws to apply those of another, it risks undermining its own sovereignty. Under the principle of , nations generally respect