Why might a court refuse to recognize a foreign judgment on public-policy grounds?

In the context of conflict of laws, a court may refuse to recognize a foreign judgment if it determines that the judgment offends the fundamental public policy of the recognizing state.1

When a court invokes this ground for refusal, it has evaluated the substantive or procedural aspects of the foreign law applied in the original case and found them incompatible with its own legal principles. By rejecting the judgment, the court effectively refuses to accept an outcome it deems contrary to its own standards of justice or law.1

Examples of this practice include:
* Punitive Damages: A German court may refuse to recognize an American judgment for punitive damages because it views such awards as exceeding the compensatory purpose of tort law.1
* Constitutional Conflicts: An American court might decline to recognize a foreign judgment if the underlying substantive or procedural law—such as specific burdens of proof—violates U.S. constitutional principles.1

Ultimately, this mechanism serves as a safeguard, ensuring that a state is not forced to enforce outcomes that fundamentally contradict its own legal or ethical framework.1