Which law governs the limitation period for registering a foreign judgment or arbitration award?
The law of the place of enforcement and in some cases, the law governing the dispute, depending on whether the limitation of rights is substantive or procedural.
If the limitation period for registering a foreign judgment is governed by the law of the place of enforcement, what is that limitation period in your jurisdiction?
Under the Reciprocal Enforcement of Foreign Judgments Act 1959 ("REFJA"), the registration needs to be done within 6 years of the date of the judgment (section 4(1)(a) REFJA). Under the Choice of Court Agreements Act 2016 ("CCAA"), an application for the recognition and enforcement of a judgment may be made any time so long as the judgment is enforceable in the state of origin (section 13(2) CCAA).