In short: a money judgment from a superior court of a "reciprocating territory" such as the UK, Singapore, the UAE, Malaysia or New Zealand can be executed directly in an Indian district court under Section 44A of the Code of Civil Procedure. A judgment from a non-reciprocating country, such as the USA or Canada, is enforced by filing a suit in India on the judgment within three years. Foreign arbitration awards from New York Convention countries are enforced under Part II of the Arbitration and Conciliation Act.
Reciprocating territories (direct execution)
The Central Government has notified, among others, the United Kingdom, Singapore, the United Arab Emirates (since 2020), Bangladesh, Malaysia, New Zealand, Hong Kong, Fiji and Trinidad and Tobago. A certified copy of the decree from a superior court there can be filed for execution in the district court where the debtor or their assets are, within the limitation period.
Non-reciprocating countries (fresh suit)
For the USA, Canada and other countries not notified, file a civil suit in India based on the foreign judgment, within three years of it. The Indian court treats the foreign judgment as conclusive unless an exception in Section 13 CPC applies.
When a foreign judgment can be resisted (Section 13 CPC)
- the foreign court lacked jurisdiction;
- it was not given on the merits (for example, a default judgment without real consideration);
- it ignored Indian law where Indian law applied, or breached natural justice;
- it was obtained by fraud, or upholds a claim that breaches Indian law.
Foreign arbitration awards
An award made in a New York Convention country notified by India (including the UK, USA, Singapore, UAE and most major trading nations) is enforced under Sections 47 to 49 of the Arbitration and Conciliation Act. Once the court rejects any objections, the award is executed as a decree. The grounds to resist are narrow, and courts favour enforcement.
Questions people ask
Can a UK court judgment be enforced in India?
Yes. The UK is a reciprocating territory, so a money decree of a superior UK court can be executed directly in an Indian district court under Section 44A CPC.
How do I enforce a US judgment in India?
The USA is not a reciprocating territory, so you file a fresh suit in India on the US judgment within three years. The Indian court generally accepts the judgment as conclusive unless a Section 13 exception applies.
Can a UAE judgment be enforced in India?
Yes. India notified the UAE as a reciprocating territory in 2020, so decrees of the UAE's superior courts can be executed directly.
How long does enforcing a foreign arbitration award take in India?
Objections must be decided first; with courts' pro-enforcement approach, this usually takes months to a couple of years, depending on the court and the debtor's assets.
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Become a ClientCall +91 81001 21141This guide gives general information about the law in India as on 11 November 2026. It is not legal advice for your situation, and reading it does not create a lawyer-client relationship. Rules and limits change; please take advice on your own facts.