In Bank of China v. Fan, 2014 BCSC 2043 the plaintiff sought to introduce several foreign judgments into evidence as proof of facts found in some of those judgments that established the essential elements of an underlying fraud. The defendants were the same parties as those against whom the prior foreign judicial determinations had been made. Skolrood J. ruled that to allow the defendants to re-litigate those essential elements of the underlying fraud would be an abuse of process.
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