The protracted legal battle originated following the September 2006 death of Davide Sidoli, who excluded Antonio and Andrea Sidoli from his will after disputing their paternity. An Italian court in Piacenza later affirmed their legitimacy and granted them a substantial sum, a verdict subsequently confirmed by the Court of Appeal of Bologna in December 2022. Seeking recovery, the brothers attempted to register the full overseas judgment in England under the Foreign Judgments (Reciprocal Enforcement) Act 1933 following a blocked attempt in June 2025. However, the High Court held that Italian authorities lack jurisdiction to decide the succession of assets physically situated in England.
Key points
English courts maintain strict limits on foreign inheritance judgments involving property…: English courts maintain strict limits on foreign inheritance judgments involving property physically located within England.
Foreign legal decisions cannot override an English will regarding succession rights to En…: Foreign legal decisions cannot override an English will regarding succession rights to English assets.
Cross-border enforcement under the Foreign Judgments (Reciprocal Enforcement) Act 1933 de…: Cross-border enforcement under the Foreign Judgments (Reciprocal Enforcement) Act 1933 depends heavily on territorial asset jurisdiction.
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A family inheritance dispute that began with a father's decision to exclude two men from his will has returned to an English court nearly two decades later. The case involved two men who claimed to be the sons of an Italian man living in England, Davide Sidoli, but were denied a share of his estate after he rejected their claims of paternity. Although Italian courts later recognised them as his sons and awarded them a combined inheritance of more than €381,000, an English court has now ruled that only a small part of that amount can be registered for enforcement in England.
In a judgment dated October 29, 2026, in Antonio Sidoli and Another v Dante Sidoli and Others ([2026] EWHC 2769 (BP)), the High Court of Justice, Business and Property Courts of England and Wales, examined whether an Italian inheritance judgment could be enforced against relatives living in England. According to the
judgment available in The National Archives, Mr Justice Thompsell allowed the registration of €46,110.07, plus applicable interest, but refused to recognise the Italian ruling to the extent…
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