Meaning
Secondary court orders obtained in a foreign jurisdiction match and enforce a primary injunction issued by the court where the main dispute is seated. Parties seek mirror injunctions to extend the geographic reach of a freezing order to other countries where the defendant holds assets or operates businesses. This prevents the defendant from evading the original court order by shifting their wealth across international borders, ensuring that the primary court’s authority is respected and enforced worldwide.
Global Execution
High-value corporate disputes often involve offshore jurisdictions where holding companies are registered. A plaintiff secures an injunction in the seat of arbitration or the defendant’s home state, then presents that order to foreign courts to freeze local bank accounts and real estate.
Judicial Comity
Foreign judges grant these supplementary orders to support international litigation and prevent their courts from being used to shelter assets from lawful claims. The court will not re-hear the merits of the underlying dispute, focus is placed on the validity of the primary injunction.
Procedural Hurdle
The applicant must satisfy the local courts that they have the jurisdiction and that the assets are located within their territory. They must also provide an undertaking in damages to the foreign court, accepting financial responsibility if the local order is later found to be improper.
