
Articles
Foreign judgments and issue estoppel: orthodoxy reasserted
In the latest edition of our commercial litigation insights series, Andreas Giannakopoulos examines the Court of Appeal's recent decision in Aviator LLC v Spribe OÜ [2026] EWCA Civ 1224, considering whether the preclusive effect of a foreign judgment on a claim made in subsequent English proceedings is governed by English law or the law applicable to the underlying claim.
By Andreas Giannakopoulos
Wednesday 28 October 2026


