Asian Priniciples For The Recognition And Enforcement Of Foreign Judgments by Adeline Chong et al. Singapore: Asian Business Law Institute, 2020. 187 pp. Hardcover: S$165.00.

This work is the second stage of a project undertaken by the Asian Business Law Institute (ABLI) to encourage the harmonisation of the recognition and enforcement of foreign judgments in the ten ASEAN Member States as well as Australia, China, India, Japan and South Korea. The first stage of the project was to produce a concise summary of the relevant law by legal experts from each of these fifteen countries. The second stage is an ambitious attempt to find commonality between these diverse jurisdictions and create thirteen core principles, which in the words of the Project Leader, Professor Adeline Chong, ‘ will provide fodder for the harmonisation of the foreign judgment rules in Asia. ’ Professor Chong stresses that these principles do not set out a model law. Nevertheless, ‘ by analysing how the countries in Asia approach specific issues and teasing out the similarities and differences between the various laws, it is hoped that they will provide a useful resource for judges, practitioners, legislators and policymakers in Asia. ’ To find commonality is no easy task, given that some of the countries in the project are common law jurisdictions, others civil and some have hybrid systems while Indonesia and Thailand do not recognise or enforce any foreign judgments. The approach adopted by the book (very much like the classic common law work Dicey, Morris & Collins on the Conflict of Laws ) is that, at the start of each section, a principle is stated and then a commentary on the principle follows. The commentary details to what degree each country within the project complies with the principle, and ends with a ‘ suggested way forward ’ which seeks to justify why the principle should form part of Asian law. To a common law lawyer, like this reviewer, there is nothing particularly controversial about ele-ven of these principles: Principle 1 (restriction on enforcement to commercial matters); Principle 2 (international jurisdiction – the need for presence or submission); Principle 3 (finality); Principle 4 (no review of the