HJ Heinz Co Ltd v EFL Inc (a Company registered in Belize) [2010] EWHC 1203 (Comm), [2010] All ER (D) 01 (Jun)
A court had to act with due circumspection when construing the effect of a foreign judgment in order to establish a case of estoppel. The judgment on the earlier action relied on as creating an estoppel had to be of a court of competent jurisdiction, final and conclusive and on the merits.
