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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. 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, according to the judgment available in The National Archives.
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. The decision turned on the limits of foreign courts’ jurisdiction over inheritance matters involving property in another country.
How the inheritance dispute began
Davide Sidoli died on September 14, 2006, after making a will dated August 22 that year. 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.
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. In the document, he left his estate to his brother Dante Sidoli and Dante’s wife, Anna Moruzzi. Mr 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.