Beals v. Saldanha was a case involving the enforcement of a foreign judgment in Canada. In other words, it was an action based on a foreign judgment. However, there is no reason why the principles articulated in that case would not also apply to the recognition of a foreign judgment when considering whether a local action is estopped. The reasons throughout speak of “recognition and enforcement” of foreign judgments. It would be illogical were the test for jurisdiction not to apply to recognition simpliciter.
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