Article 34

A judgment shall not be recognised:

1.if such recognition is manifestly contrary to public policy in the Member State in which recognition is sought;

2.where it was given in default of appearance, if the defendant was not served with the document which instituted the proceedings or with an equivalent document in sufficient time and in such a way as to enable him to arrange for his defence, unless the defendant failed to commence proceedings to challenge the judgment when it was possible for him to do so;

3.if it is irreconcilable with a judgment given in a dispute between the same parties in the Member State in which recognition is sought;

4.if it is irreconcilable with an earlier judgment given in another Member State or in a third State involving the same cause of action and between the same parties, provided that the earlier judgment fulfils the conditions necessary for its recognition in the Member State addressed.