Law & Justice

English Court Allows Partial Registration of Italian Inheritance Judgment

By

English Court Allows Partial Registration of Italian Inheritance Judgment

A dispute over the estate of Italian expatriate Davide Sidoli, who died in England in 2006, has returned to an English court nearly two decades later. Sidoli’s will, dated 22 August 2006, left his estate to his brother Dante Sidoli and Dante’s wife Anna Moruzzi, explicitly excluding his former wife’s two sons, Antonio and Andrea Sidoli, whom he did not consider his biological children. The two men challenged the exclusion, claiming paternity. In 2020 a court in Piacenza recognized them as legitimate heirs and awarded them €381,796.31, plus interest and other relief. Dante and Anna appealed, but the Court of Appeal of Bologna dismissed the appeal in December 2022.

Although the Italian ruling was favourable to Antonio and Andrea, they needed to secure its enforcement against the respondents in England. They applied under the Foreign Judgments (Reciprocal Enforcement) Act 1933. An earlier registration order was set aside in June 2025 when Deputy Master Dew found that the Italian courts had no jurisdiction over the succession of an estate of a person domiciled in England. The men appealed.

In the High Court of Justice, Business and Property Courts, Mr Justice Thompsell examined the Italian judgment in detail. He held that Italian courts could determine succession to property situated in Italy, but could not decide the validity of an English will or the succession to assets located in England. Consequently, the judgment was partially recognised. The court calculated the value of Sidoli’s Italian estate, including the inheritance he had received from his father Quintilio, at €410,855.93. Antonio and Andrea were entitled to a combined two‑thirds share, amounting to €273,923.95. The value of the Italian immovable property to be transferred to them was €45,865.79. Using this figure, the court allowed registration of €46,110.07 (the €45,865.79 plus €244.28 for appeal costs). Italian statutory interest from 21 February 2020 will also be added.

The decision does not resolve the broader family dispute or determine ownership of Sidoli’s English assets. It merely establishes that a portion of the Italian inheritance award can be recognised for enforcement in England. Antonio and Andrea now have a small part of their claim enforceable, while the larger portion of the Italian award remains unenforceable in England through this registration route.

Frequently asked questions

How much of the Italian inheritance award was registered for enforcement in England?

The court allowed registration of €46,110.07, which includes €45,865.79 for Italian immovable property and €244.28 for appeal costs.

Why was the Italian judgment only partially recognized by the English court?

The court held that Italian courts can decide succession to property in Italy but cannot determine the validity of an English will or succession to assets in England, so only the portion relating to Italian property was recognized.

What was the total value of Sidoli's Italian estate as calculated by the High Court?

The High Court calculated the value of Sidoli's Italian estate, including inheritance from his father Quintilio, at €410,855.93.

Related stories