would allow foreign judgments to shape the English common law. By contrast, Adams v Cape Industries plc specifically rejected comity as the basis for recognition or non-recognition of judgments because it was insufficiently hard-edged for the demands. However, comity remains valuable for examining the doctrine of recognition insofar as it underpins the principle that a domestic court cannot examine the substantive validity of the foreign court's action – as it cannot claim to hold more competence – nor does it pretend that it must enforce the foreign court's decision. Comity for the sovereignty of courts is insufficient for enforcing recognition because does not consistently determine a stringent enough rule for when sovereignty is to be accepted as a proper application onto the parties and when it is not recognised on the grounds that the parties ought not to be bound. The Canadian approach, set forth in Beals v Saldanha, was one of a more open enforcement of foreign judgments by enforcing the foreign judgment if the foreign jurisdiction can be determined (by the Canadian court) as being the natural forum for the resolution of the dispute, or that there was a real and substantial connection between the foreign jurisdiction and the dispute. This is a substantial deviation from the English approach, and one that, in the English context, would bring forth more problems than it would solve. By contrast, the doctrine of obligation, engaged between the two adjudicating parties, underpins the English approach. It focuses on the action of the defendant, whereas the Canadian approach does not focus on the defendant's action. Common law recognition rules The first of two broad bases for recognition within the Common law rules in England and Wales is set forth in Adams v Cape Industries plc. Where a party was present within the territory of the adjudicating court when proceedings instituted, the court will bind the party to the decision of the court so long as the adjudications are recognised as conclusive. The question of whether the judgment will be enforced will be a separate matter. Secondly, if a party is shown to have agreed with his opponent, by word or action, to abide by the judgment of the court, private agreement is sufficient for recognising the substance of the judgment as res judicata. Only English judgments are recognised in England, if the foreign court is competent, under English rules, and there is no