一、比较法上的概述有必要先瞭解当前国际上的一般做法。根据一般理解,国际间的承义和执行分属两个有联系的不同范畴:承认是指一国法院认可外国判决与本国判决具同等效力;执行是指外国判决当事人一方不执行判决,一国法院以强制手段执行所承认的境外判决。可见,承认是前提,执行是承认的延展;但是承认并非一定要执行,尤其是宣告式的判决。在一般情况下,人们会更注重承认问题,因为在承认问题解决后,执行问题是顺理成章的事。在实践中,对外国判决的承 First, an overview of comparative law It is necessary to understand the current international practice. According to the general understanding, international betrayal and enforcement fall into two different connected categories: recognition refers to the fact that courts in one country recognize foreign judgments as having the same validity as domestic judgments; enforcement means that one of the parties to a foreign judgment does not enforce the judgment. One country The court enforced recognized overseas judgments by force. It can be seen that recognition is a prerequisite and that execution is an extension of recognition; however, recognition does not necessarily mean that it must be implemented, especially pronounced judgments. Under normal circumstances, people will pay more attention to recognize the problem, because the implementation of the issue is a matter of course after acknowledging the solution of the problem. In practice, the acceptance of foreign judgments