P St J Smart (University of Hong Kong) has written an article in the latest Australian Law Journal (2007 vol 81, p 349) on the question of whether an Australian court may enforce a foreign judgment which is itself founded upon the judgment of another, different foreign court. The abstract continues:
The enforceability of a so-called “judgment on a judgment” has been canvassed by academic writers and has the support of at least one recent case (albeit not in an Australian court). Yet this commentator suggests that an Australian court should not enforce the judgment of an intermediary foreign court because such judgment will not meet the requirement that it is a decision on the merits of the parties’ dispute.
The article takes as its starting point the recent Hong Kong decision in Morgan Stanley & Co International Ltd v Pilot Lead Investments Ltd  4 HKC 93;  HKCFI 430, which concerned the enforcement in Hong Kong of an Singaporean order which was in turn based upon the registration of an English judgment.
The article is available on the internet to Lawbook Online subscribers.