In the early days such a mutuality may be difficult to substantiate – as between the PRC and a given foreign country the issue will arise for the first time and there will be no prior practice between the two that can be referred to, as a basis for asserting mutuality. It may be that a country with a developed legal system does have a history of foreign judgment recognition independently of treaty obligations made good through legislation by, for example, domestic legislative provision for foreign judgment enforcement, or in the case of the common law jurisdictions, by a process of judicial precedent.