The Law Reports (Queen's Bench Division)
[2020] QB 971
Queen’s Bench Division
MAD Atelier International BV
v
Manès
[2020] EWHC 1014 (Comm)
2020 March 10, 11; April 28
Bryan J
Estoppel— Per rem judicatam— Issue estoppel— Judgment of foreign court— French court giving judgment in claim between claimant and companies wholly owned by controlling shareholder— Claimant subsequently starting proceedings against controlling shareholder in English court— Whether claim to be struck out as abuse of process on basis French judgment giving rise to issue estoppels— Whether foreign judgment capable of giving rise to issue estoppel in English proceedings if foreign legal system having no doctrine of issue estoppel— Whether parties or their privies identical in both sets of proceedings where shareholder and wholly-owned companies respectively being defendants