In Vrbica v Croatia (32540/05) [2010] ECHR 424, the European Court of Human Rights (ECHR) considered whether there had been a breach of Article 1 of Protocol 1 (protection of property) and Article 6 (right to a fair hearing) of the European Convention on Human Rights (the Convention), because of the refusal of the Croatian courts to enforce a judgment, given by a court in Montenegro and judicially recognised in Croatia, on the grounds that it was time-barred.

The ECHR held that instituting proceedings for the recognition of a foreign judgment would interrupt the running of the statutory limitation period and it was untenable to hold otherwise. Croatia had violated Article 1 of Protocol 1 and Article 6. It should be noted that, although the judges came to a unanimous conclusion, their reasoning on Article 6 was different.