Two decisions on the enforceability of British libel judgments in the United States—
Bachchan v. India Abroad Publications Inc.35 and Telnikoff v. Matusevitch36—form the
bedrock of the doctrine on the public policy exception in the context of foreign
judgments involving the First Amendment. In both these cases, U.S. courts carefully
analyzed and compared British and American libel laws to conclude that enforcing
British libel judgments in American courts would violate the public policy of the
states where the cases arose.37 While scholars have often criticized the public policy
analysis in these two cases,38 Bachchan and Tenikoff remain the foundational decisions