The effect of the UK Supreme Court’s decision in Drelle v Servis-Terminal LLC [2026] UKSC 29 is that it may be easier to wind up a company or bankrupt an individual on the basis of a foreign judgment from a country with no UK registration or recognition regime than one with such arrangements, by removing doubt as to whether such a judgment gives rise to a “debt” for these purposes. The Court confirmed that an unrecognised foreign judgment debt can directly found a statutory demand or insolvency petition, without going through the process of first seeking recognition of the judgment. The decision resolves last year’s Court of Appeal uncertainty, leaving open for future review a striking paradox at the heart of English cross-border…

