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
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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 law of the place where the wrong (tort) was committed.
