| Sumario: | "When a foreign judgment is recognized, what exactly is it that is recognized? Here there seems to be a difference between the common law and the civil law. In the civil law, it is sometimes said that the final ruling or order (in German, the Tenor or Spruch; in French, the dispositif) is all that is recognized. In the common-law world, however, the doctrine known variously as issue estoppel,2 collateral estoppel or issue preclusion3 requires a court in certain circumstances to recognize rulings by the court of origin on preliminary issues.4 Estoppel is a doctrine peculiar to the common law. It is too complex to sum up in a few words, but the underlying idea may be explained by saying that a person should not be allowed to say one thing at one time and another thing at another 2 British and Commonwealth terminology. 3 These latter two expressions are both United States terminology. 4 This raises the question which law should decide whether issue estoppel applies: should it be the law of the State of origin or that of the State of recognition"--
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