Res judicata is one of the main legal effects of a court judgment. Res judicata results from the award at the date of its issuance. This effect applies to both national and international judgments.

However, under private international law, French and Jordanian courts have not recognized res judicata of a foreign judgment before the issuance of execution order. As I don't agree with this conclusion, I have decided to address this subject in two chapters. Chapter one is devoted to the res judicata under French law while chapter two tackles the issue under Jordanian law. At the end I concluded this study with a conclusion and recommendations.

Key words: foreign judgment, res judicata, execution order, Jordanian law, French law