قوة الحكم الجزائي الأجنبي أمام القضاء الوطني

Abstract EN

The penal judgment has two effects: negative and positive.

The former one is obtained from the devoted principle in internal laws and it is double jeopardy which means that the disciplinary judgment has the authority of the final decision in front of the national public authorities, but the principle is not absolute, countries have already worked with it using different provisions from a country to another.

The same thing for the later one (positive effect) despite the orientation towards the approval of the implementation of foreign penal provisions outside the country borders that issued a writ.

However, the majority of state legislation is still influenced by the idea of sovereignty, so it does not accept it, unless there are conditions such as the existence of an international convention that biases it.