What defences can a defendant seek to impeach a foreign judgment?

Once a “real and substantial connection” is found to apply with respect to a foreign judgment, the defendant may still impeach the foreign judgment, and thereby avoid its recognition and enforcement, by establishing any of the available “defences.” More specifically, the defendant may seek to establish: (1) that the foreign judgment was obtained by fraud; (2) that the foreign proceedings were conducted in a manner contrary to the rules of natural justice; or (3) that recognition and enforcement of the foreign judgment would be contrary to public policy. These defences are designed to guard against potential unfairness in the enforcement of foreign judgments. See: Beals v. Saldanha, at para. 35, 39-41.