CPC- Sec 13 Foreign Judgment Renusagar Power Co. Ltd. v. General Electric Co., AIR 1994 (SC) 860 With regard to enforcement of foreign judgments, the position at common law is that a foreign judgment which is final and conclusive cannot be impeached for any error either of fact or of law and is impeachable on limited grounds, namely, the court of the foreign country did not, in the circumstances of have jurisdiction to give that judgment in the view of English law; the judgment is vitiated by fraud on part of the party in whose favour the judgment is given or fraud on the part of the court which pronounced the judgment; the enforcement or recognition of the judgment would be contrary to public policy; the proceedings in which the judgment was obtained were opposed to natural justice. In the field of private international law, Courts refuse to apply a rule of foreign law or recognise a foreign judgment or a foreign arbitral award if it is found that the same is contrary to the public policy of the country in which it is sought to be invoked or enforced. Redfern and Hunter, "if a workable definition of "international public policy" could be found, it would be an effective way of preventing an award in an international arbitration from being set aside for purely domestic policy considerations".