English to French Law/Patents Law (general) Foreign judgments

Salut,

By the Civil Liability (Contribution) Act, any person liable in respect of any damage may recover from another person liable of the same damage...

The view has been expressed that a foreign judgment give no right to seek contibution under the 1978 Act. The question was left open in the Privy Council but it indicated that the argument that the 1978 Act did not apply to foreign judgments had some substance. It is suggested that these doubts are well-founded, unless a foreign judgment, in proceedings to which the person from whom contribution is sought is a party, has held him liable and is entitled to recognition as against him.

Merci