What is meant by a violation of “State sovereignty or security and social public interest” of the PRC? These terms are not defined. The terminology is expansive and gives the court a considerable discretion in matters of this type. Grounds for concluding that a judgment ought not to be enforced under this head would presumably include that the judgment of the foreign court was procured by fraud or that it did not observe due process or natural justice in its conduct of the case in question, or that enforcement of the judgment would involve enforcement of a foreign penal or taxation law, or would involve enforcement of the interest of a foreign government, or that enforcement would be against public policy. These are familiar ground for refusing enforcement of foreign judgments in common law courts.