In 2006, an Italian father living in England excluded two men from his will, denying they were his sons; 20 years later, an English court has allowed only €46,110 of a €381,796 Italian inheritance judgment to be registered

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 that it dealt with assets situated in England. The decision turned on the limits of foreign courts' jurisdiction over inheritance matters involving property in another country.How the inheritance dispute beganDavide Sidoli died on September 14, 2006, after making a will dated August 22 that year. In the document, he left his estate to his brother Dante Sidoli and Dante's wife, Anna Moruzzi. He specifically excluded his former wife's two sons, Antonio and Andrea Sidoli, stating that he did not consider them his biological children and therefore did not believe he had a moral obligation to leave them anything.Antonio and Andrea challenged this decision, maintaining that Davide was their father. The dispute also involved the earlier estate of Davide's father, Quintilio Sidoli, who had died in 2004 and had left property and other assets to Davide. Both Davide and Quintilio were Italian citizens but were domiciled in England when they died.The two men began legal proceedings in Italy in 2012. On February 21, 2020, a court in Piacenza accepted their claim of paternity, declared them legitimate heirs and set aside the relevant provisions of Davide's will. It awarded them €381,796.31, along with legal interest and other relief. Dante and Anna challenged the decision, but the Court of Appeal of Bologna dismissed their appeal on December 28, 2022.Why the case reached an English courtAlthough Antonio and Andrea had secured a favourable ruling in Italy, they still needed to establish that it could be enforced against the respondents in England. They therefore approached the English courts under the Foreign Judgments (Reciprocal Enforcement) Act 1933. Their initial attempt to register the Italian judgment was challenged. An earlier registration order was cancelled after the respondents applied to have it set aside. In June 2025, Deputy Master Dew refused the application, finding that the Italian courts did not have jurisdiction to determine the succession to the estate of someone domiciled in England.Antonio and Andrea appealed that decision. Their argument was that the Italian courts had the authority to decide inheritance matters concerning assets located in Italy, even if the wider estate included property in England. The respondents, meanwhile, argued that the Italian judgment should not be enforced because it had attempted to invalidate an English will and determine the inheritance of assets belonging to a person domiciled in England.Court separates Italian and English propertyMr Justice Thompsell examined the different parts of the Italian ruling rather than treating it as one indivisible decision. He explained that English law could recognise the jurisdiction of Italian courts over property situated in Italy, but not their authority to decide the validity of an English will or determine succession to assets located in England. The judge also considered the principle of reciprocal enforcement, under which foreign judgments can be recognised when the relevant legal requirements are met. He noted that the Italian courts' authority over inheritance matters did not automatically extend to property outside Italy.As a result, the judge partly allowed the appeal. He ruled that the Italian judgment could be registered insofar as it concerned the succession to Italian property belonging to Quintilio and Davide. However, the parts relating to Davide's English estate and the validity of his English will could not be enforced through this route.How the court arrived at €46,110The court then worked out how much of the original award related to property that the Italian courts had authority to deal with. It calculated the value of Davide's Italian estate, including the inheritance he had received from Quintilio, at €410,855.93. The Italian inheritance rules allowed Antonio and Andrea to claim a combined two-thirds share of Davide's estate, calculated at €273,923.95.The value of the relevant Italian immovable property transferred, or to be transferred, to Antonio and Andrea was much lower, at €45,865.79. The judge used this figure to determine the proportion of the inheritance award that could be registered in England. He also added €244.28 towards the appeal costs, bringing the total to €46,110.07. Applicable Italian statutory interest from February 21, 2020, will also be added to this amount.The judgment does not resolve the wider family dispute or determine the ownership of Davide's English assets. Instead, it establishes how much of the Italian inheritance ruling can be recognised for enforcement in England. Nearly 20 years after Davide's death, Antonio and Andrea have secured recognition of part of their inheritance claim, while the larger portion of the Italian award cannot be enforced in England through this registration.You use AI every day. Now get your AI Quotient. Take the AIQ test.