Questione giuridica chiave
Whether the French judgment could be enforced in Switzerland under the Lugano Convention despite the debtor's objection based on public policy because the foreign court allegedly ruled ultra petita.
Decisione estratta
No. The alleged ultra petita ruling concerned only provisional enforceability and did not amount to a grave violation of the right to be heard or Swiss public policy.
Motivazione estratta
The parties had been heard on the merits of the monetary claims; the ex parte concern related only to provisional execution, which does not create a definitive legal situation. Recognition cannot be refused for every procedural deviation, only for a serious one.