State Immunity from Execution of Foreign Judgments: Making Sense of Jurisdictional Issues in the Requested State

State immunity represents a procedural bar either to the execution of a judgment or the enforcement of any measure of constraint adopted before, during or after the proceedings on the merits. State immunity operates with regard to foreign and domestic judgments. This paper engages with the questions concerning jurisdiction that seem to arise in relation to a request of exequatur and execution of foreign judgments when issues of State immunity are at stake, finding that not everything on the matter is as real as it seems.