There is much to be said about the refusal of the courts at Zurich at the end of February, to recognise a September 2020 High Court judgment under the 2007 Lugano Convention. Rodrigo Rodriguez says it all here and I am happy to refer. The guillotine fashion in which the courts rejected application of Lugano 2007 even for a procedure that was initiated before Brexit date 1 January 2021 leaves much to be discussed. As does the question whether the demise of Lugano 2007 might not resurrect Lugano 1988 (Rodrigo points ia to the dualist nature of the UK in his discussion of same).
Whether correct or not in the specific case at issue, the judgment does show the clear bumpy ride ahead for UK judgments across the continent, following the Hard Brexit in judicial co-operation.
Geert.
EU Private International Law, 3rd ed., 2021, Chapter 1, Heading 1.7.
gavc law - geert van calster 