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Practice Guide · 8 September 2026

A Decree from Abroad: Enforcing Foreign Judgments in Indian Courts

Reciprocating territories get direct execution under Section 44A; everyone else must sue on the judgment — and every foreign decree must survive the six tests of Section 13.

Cross-border commerce produces cross-border judgments: a supplier wins in London, an investor in Singapore, a family member in Dubai — and the defendant's assets are in Delhi. Whether that foreign judgment can be converted into recovery in India depends on a compact statutory scheme: Section 44A of the Code of Civil Procedure, 1908 for decrees of superior courts of "reciprocating territories", a suit on the foreign judgment for everywhere else, and, in either route, the conclusiveness tests of Section 13. This article explains the two routes, the defences the judgment-debtor can raise, and the practical steps that decide how fast a foreign decree bites in Delhi.

The two routes at a glance

Reciprocating territory (Section 44A)

File a certified copy of the decree of a notified superior court, with a certificate of satisfaction status, in the Indian district court where execution is sought. The decree is executed as an Indian decree — no fresh suit, no re-trial of the claim.

Non-reciprocating territory (suit on the judgment)

Institute a suit in the competent Indian court using the foreign judgment as the cause of action. The trial is ordinarily confined to the Section 13 defences; success yields an Indian decree, which is then executed in the usual way.

The difference is time and vulnerability: Section 44A execution begins where litigation normally ends, while the suit route re-enters the queue of civil litigation — though summary procedures can shorten it where no triable defence under Section 13 exists.

Section 13: the six gates every foreign judgment must pass

Jurisdiction in the international sense. The foreign court must have had jurisdiction over the defendant by residence, submission, or agreement. A default judgment against a defendant who never traded in, appeared in, or agreed to that forum is the classic casualty.
Merits, not default formalism. The judgment must reflect adjudication on the merits. Purely technical or penal defaults, where the claim\'s substance was never examined, fail this test even if procedurally regular abroad.
Natural justice and fraud. Proper notice and opportunity to be heard are scrutinised; and fraud — on the foreign court or on the opposite party — unravels conclusiveness whenever discovered.
Conformity with Indian fundamentals. Judgments founded on refusal to recognise applicable Indian law, or sustaining claims that breach Indian law, are denied recognition — the gate through which public-policy style objections enter.

Practicalities that decide speed

Documentation. For Section 44A: certified copy of the decree and the certificate regarding extent of satisfaction from the foreign court, with authentication. Deficient paperwork is the commonest cause of delay at institution.
Forum and assets. Execution is filed where the judgment-debtor\'s assets are — in Delhi, the district court with territorial jurisdiction over the assets; asset tracing should precede filing, and disclosure mechanisms in execution can supplement it.
Debtor\'s objections. Expect the Section 13 defences to be run as execution objections; they are decided by the executing court, and interim protection of assets pending decision can and should be sought.
Conversion and interest. The decretal sum is realised in rupees; exchange-rate date and post-decree interest treatment should be addressed in the execution application rather than left to later contest.

Foreign arbitral awards are a different highway altogether: New York Convention awards are enforced under Sections 44 to 49 of the Arbitration and Conciliation Act, 1996, not under Section 44A CPC. Choosing the wrong vehicle for the instrument in hand is a recurring and wholly avoidable error.

Planning points for cross-border creditors

Check reciprocity and the notified "superior court" status of the judgment-forum before choosing the route.

Sue where the defendant\'s assets are reachable; a swift foreign judgment against an India-asset defendant is only as good as its Indian enforcement plan.

Anticipate Section 13 at the drafting stage of the foreign proceedings: proper service, reasoned judgments on merits, and clean jurisdictional foundations pay off in India years later.

Diarise limitation for the enforcement step itself and act promptly — staleness breeds objections.

India enforces foreign judgments through a defined, workable scheme — direct execution for the notified few, a judgment-based suit for the rest, and the Section 13 gates for all. Creditors who prepare for the Indian leg from the outset convert foreign paper into Indian recovery with far less friction. This article is general information and is not legal advice on any individual case.

Frequently Asked Questions

What is a reciprocating territory?

A country or territory notified by the Central Government under Section 44A — the United Kingdom, Singapore and the United Arab Emirates are prominent examples, among others notified over the years. Decrees of the notified "superior courts" of such territories may be executed in India directly, as if passed by the Indian district court in which the certified copy is filed.

What if the judgment is from a non-reciprocating country, like the United States?

Direct execution is unavailable. The judgment-creditor must file a suit in India on the foreign judgment (or on the original cause of action), within the limitation period, and obtain an Indian decree — with the foreign judgment serving as evidence creating a strong presumptive case, subject to the Section 13 defences. The Indian decree is then executed normally.

What defences can the judgment-debtor raise?

The six exceptions in Section 13: the foreign court lacked jurisdiction in the international sense; the judgment was not on the merits; it appears on its face to be founded on an incorrect view of international law or a refusal to recognise applicable Indian law; the proceedings were opposed to natural justice; the judgment was obtained by fraud; or it sustains a claim founded on a breach of Indian law. These apply in execution under Section 44A just as in a suit.

Can execution under Section 44A cover any kind of foreign order?

No. The route is confined to decrees for the payment of a sum of money, excluding taxes, fines, penalties and amounts payable under arbitration awards — foreign arbitral awards travel under the separate enforcement regime of the Arbitration and Conciliation Act, 1996. Injunctions and specific-performance orders also fall outside Section 44A.

Note: This article is general information about the law and is not legal advice. It does not create an advocate-client relationship. The position stated is as at 8 September 2026 and may have changed since. Readers should verify any provision or decision referred to against the official text and seek advice on their own circumstances.