In case an international civil or commercial dispute arises, certain foreign courts have jurisdiction; while Chinese courts have jurisdiction too. It is possible both a Chinese court and a foreign court could issue judgment (sometime different judgment) upon the same matters at the same time. Gerally speaking, Chinese courts do not deny the legal effect of the foreign judgment in the territory of the foreign country. However, the judgment  rendered in the foreign country which is expected to be enforced in the territory of P. R. China must be supervised by a Chinese court and meet the condition: treaty or “under the principle of reciprocity”.

Article 281 of Civil Procedure Law of the People's Republic of China states,
"Where an effective judgment or ruling of a foreign court requires recognition and enforcement by a people’s court of the People’s Republic of China, a party may apply directly to the intermediate people’s court of the People’s Republic of China having jurisdiction for recognition and enforcement or the foreign court may request recognition and enforcement by the people’s court in accordance with the provisions of an international treaty concluded or acceded to by the People’s Republic of China or under the principle of reciprocity."
Article 282 further stipulates,
 “After examining an application or request for recognition and enforcement of an effective judgment or ruling of a foreign court in accordance with an international treaty concluded or acceded to by the People’s Republic of China or under the principle of reciprocity, a people’s court shall issue a ruling to recognize the legal force of the judgment or ruling and issue an order for enforcement as needed to enforce the judgment or ruling according to the relevant provisions of this Law if the people’s court deems that the judgment or ruling does not violate the basic principles of the laws of the People’s Republic of China and the sovereignty, security and public interest of the People’s Republic of China. If the judgment or ruling violates the basic principles of the laws of the People’s Republic of China or the sovereignty, security or public interest of the People’s Republic of China, the people’s court shall not grant recognition and enforcement.”

The writer has carried out comprehensive and thorough legal research upon the multilateral convention or bilateral treaty acceded to or concluded by China with respect to recognition and enforcement of an effective court judgment or ruling rendered in a foreign  country. It is a pity so far China has not yet acceded to  any multilateral convention; while China has concluded bilateral judicial assistance treaties only with 39 countries (38 of which have taken effect). In addition, not all  bilateral judicial assistance treaties  address recognition and enforcement of an effective court judgment or ruling rendered in the other country.

As far as “under the principle of reciprocity” is concerned,currently the interpretation and application of the principle of reciprocity by Chinese judges is very conservative and much strict.Please note that in light of Chinese judicial practice, Chinese judges interpretate “under the principle of reciprocity” as “a court of the foreign country in question has already recognized an effective judgment or ruling of a Chinese court”; otherwise, the Chinese court will reject recognition and enforcement of an effective judgment or ruling of a foreign court by reason of “lack of reciprocity relationship”.

For example, although USA, Germany and Israel  have not yet concluded any bilatetral judical assistance treaty with China, the courts of the three countries have already recognized  a judgment or ruling issued by Chinese courts. It is possible that Chinese courts may recognize and enforce judgment /rulings rendered by the courts of the USA, Germany and Israel.