Question juridique clé
Whether the French divorce judgment was an enforceable title for definitive debt enforcement in Switzerland
Solution extraite
Yes. The foreign judgment was executable in France and could serve as a title for definitive lifting once its recognition and enforcement were established incidentally.
Motifs extraits
For a foreign judgment rendered before the revised Lugano Convention entered into force in Switzerland, the old Lugano Convention applied. The Swiss enforcement judge could interpret the foreign judgment in light of the foreign law and did not need to re-examine Art. 80 LP once exequatur was incidentally granted.