The effect of foreign penal judgment within the national territory (A comparative study)

Abstract

Some believe that the reccgnition of foreign penal judment as a national one is a violation of national sovereignty, Where as the first is issued by a foreign court of law and on behalf of the foreign judiciary, while the second is issued on behalf of the national judiciary, regardless of the nationality of the judge or the place where it was rendered. Scholars differed on the recognition of the effects of foreign penal sentences between supporters (modern trend), which support the need to recognize the effects of the Foriegn penal judgment, and these who deny all value for Foriegn peral judgmerts. This study exanines of the effect of foreign penal judgments within the national territory in Jordanian legislation and international conventions as a comparative study between the Jordanian, Egyptian and Bahraini legislations. Emphasis was placed on the ruling of a negative nature and also these that have provisions of the positive character. The study concluded with suggestion for further recommendations.