application of the foreign law and of the foreign court’s jurisdiction on the matter.36 They
are not, however, necessarily binding on Quebec courts.37
 In this case, the trial judge decided to place no weight upon the decision of the
Greek court of first instance presided by Judge Kostis which, on December 16, 2013,
dismissed Eurobank’s injunction proceedings in Greece. The trial judge was of the view
that this decision was not consistent with the conduct of the Greek Ministry of National
Defense as had been established before him at the hearing of this case. In the trial judge’s
view, this conduct clearly amounted to fraud since it sought to circumvent, through clumsy
and obvious means, both the Interim Order and the Final Award of the ICC Arbitral
Tribunal.38 Likewise, no weight should be given to the decision of the Court of Appeal of
 Although it appears from the decision of the Court of Appeal for Athens that, under
Greek law, the written commitments of the Greek Ministry of National Defense as well as
binding arbitration proceedings involving that Ministry are unenforceable within Greek
territorial jurisdiction, Quebec courts are not bound to recognize and enforce such foreign
laws and decisions within Quebec with respect to Quebec when the result of doing so is
manifestly inconsistent with public order as understood in international relations. A
minimal degree of international business morality and fair play can prevail and be
enforced outside the ambit of Greek territorial jurisdiction. This is, moreover, the case
where, as here, no formal request for recognizing this foreign judgment has been made
by any party.
 In this context, though the principle of international comity is a guiding principle for
Quebec courts when considering or enforcing foreign judgments,39 this principle must be
applied with regard to other values, including those of order and fairness so as to avoid
injustice40 and that of reciprocity.41 This is why public policy considerations may compel
a Quebec court to disregard a foreign law or a foreign judgment,42 more particularly when
Catherine Piché, La preuve civile, 5th ed., Montreal, Yvon Blais, 2020, p. 259; Gérard Goldstein and
Ethel Groffier, Traité de droit civil – Droit international privé, vol. 1, Cowansville, Yvon Blais, 1998,
Canadian Forest Navigation Co. Ltd. v. Canada, 2017 FCA 39, paras. 19-20; J.-G. Castel, Droit
international privé québécois, Toronto, Butterworths, 1980, p. 846.
Trial judgment, paras. 189-191.
Spar Aerospace Ltd. v. American Mobile Satellite Corp., 2002 SCC 78,  4 S.C.R. 205, paras.
15-19 (“Spar Aerospace”); Beals v. Saldanha, 2003 SCC 72,  3 S.C.R. 416, paras. 27-28
Spar Aerospace, para. 20; Beals, paras. 39-41.
Beals, para. 29.
R.S. v. P.R., 2019 SCC 49 (),  3 SCR 643, paras 52-53; Beals, paras. 71-72; Pro Swing
Inc. v. Elta Golf Inc., 2006 SCC 52,  2 S.C.R. 612, paras. 12, 26-27; Smart Systems Technologies
Inc. v. Domotique Secant inc., 2008 QCCA 444; Claude Emmanuelli, Droit international privé
québécois, 3rd ed., Montreal, Wilson & Lafleur, 2011, paras. 298-299; Gérard Goldstein and Ethel
Groffier, Traité de droit civil – Droit international privé, vol. 1, Cowansville, Yvon Blais, 1998, para. 165.