نظام تنفيذ الأحكام الأجنبية في القانون الدولي الخاص المغربي

الملخص EN

This paper treats the matter of foreign judgements execution.

In the course of our study, we found that there are two fundamental systems in the field of foreign judgments execution, the first is known as the new lawsuit system or the review method, and the second is the monitoring system, also known as the execution order system, to conclude at the end of the research the importance of the execution order system, which has become accepted by most legal systems.

Indeed this seems evident to us through Moroccan private international law, which in turn adopted the execution order system, whereby the implementation of the foreign judgment in Morocco depends on the national judge issuing the order to append it to the executive formula once it fulfils all the conditions contained in the civil procedure law that are in line with the conditions in force in the order system in general.