The UK decision in Rubin v. Eurofinance [2012] UKSC 46 arises from two appeals: Rubin v Eurofinance SA (???Rubin???) and New Cap Reinsurance Corpn Ltd v Grant (???New Cap???), both dealing with the issue of whether an order or judgment of a foreign court (on these appeals the United States Bankruptcy Court for the Southern District of New York, and the New South Wales Supreme Court) in proceedings