1A judgment of a People's Court of the People's Republic of China is enforceable at common law in New South Wales where the four requirements of jurisdiction, finality, identity and a fixed liquidated sum are established, following Bao v Qu; Tian (No 2) (2020) 102 NSWLR 435.
2Interest imposed under Art 264 of the Civil Procedure Law of the PRC (formerly Art 253) is compensatory rather than penal in nature and is therefore not excluded from enforcement by the principle that Australian courts will not enforce foreign penal laws, following Shanghai Chenggong Industrial Co Ltd v Zhihua Chen [2025] NSWSC 1112.
3The withdrawal of an appeal against a foreign judgment confirms its finality for the purposes of common law enforcement in Australia.
