The Italian Court of Cassation, in its Order No. 10307/23, published on 18 April 2023, confirmed that, under Article 3(1)(b) of the Convention between Italy and Tunisia of 15 November 1967 on Judicial Assistance in Civil, Commercial and Criminal Matters, a judgment cannot be recognised in the other State if the defendant – not located in the territory of the State in which the judgment was given – was given a time limit for appearance of less than 90 days, and this even if the defendant had entered an appearance.

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