a party from bringing another action against him in England. By contrast, should a party succeed in a foreign action, he may seek to enforce the action in England. The judgment creditor need not have to succeed at every point within the foreign action. It had previously been the case that if the foreign claimant had been partially successful, he was entitled to sue on the cause in action again within England. Section 34 of the Civil Jurisdiction Judgment Act 1982 was subsequently passed by parliament to remove the right to sue a second time. A court's judgment is an exercise of sovereign power; it is this principle that underpins the English position that no foreign judgment will have an effect in England and, conversely, that the English courts cannot expect an English judgment to have any effect abroad. Exceptions to the limitation on foreign judgments are set out through parliament. The Brussels Recast Regulation operates as the primary procedural scheme relating to foreign judgments, their recognition and enforcement. Recognition is automatic between member states, barring exceptions set out in Chapter III of the regulation. This is consistent with the EU principles of a single economic market where courts and government departments can be trusted to get things right. Under the common law, recognition is limited to a certain set of criteria. As adjudication is considered a sovereign act, the common law has developed the concept of comity to determine circumstances where recognition and enforcement acknowledged and respected the foreign sovereign act sufficiently to enforce it domestically. This was pioneered in Hilton v Guyot. A judgment may therefore be reduced to four components: The foreign judgment has no force, as a judgment, outside the place it was given because adjudication is an act of sovereign power; Comity favours giving effect to foreign judgments and the question then is as to which foreign judgments ought to be recognised; If the parties have had a full and proper trial before a reasonable court, the judgment is accepted at face value as res judicata; If the law of the court which has adjudicated would not accept an equivalent judgment at face value, it will not enjoy reciprocity. Reciprocity is not the central tenet of recognition, but rather it is suggested that it is the doctrine of obligation. This sits at the apex of an interplay between sovereignty, comity, consent, and reciprocity. Accepting reciprocity