The High Court has recognised a Northern Ireland personal insolvency arrangement in the Republic of Ireland, extending principles previously used in cross-border corporate insolvency cases to an individual debt arrangement.
The application was brought by Northern Ireland insolvency practitioner Séamas Keating in relation to an Individual Voluntary Arrangement, or IVA, entered into by Raymond Hugh Gallogly. An IVA is a statutory agreement under which creditors can accept a structured settlement of debts as an alternative to bankruptcy.
Gallogly, a self-employed tiler whose main centre of interests was in Northern Ireland, owed Bank of Ireland £150,000 and another creditor £8,000. His mother provided £10,000 for distribution under the arrangement. Bank of Ireland voted in favour of the proposal.
The IVA was approved by creditors on October 19, 2023 and registered in the High Court in Northern Ireland. However, because of legal changes following Brexit, Bank of Ireland required an Irish court order before it could process the dividend and give Gallogly the benefit of the agreed write-off.
In an ex tempore judgment delivered on December 1, 2025, Mr Justice Oisín Quinn held that the High Court has an inherent jurisdiction to recognise foreign insolvency proceedings outside the European Union. Previous Irish cases had applied that principle to corporate insolvencies; the present application asked the court to extend it to a personal insolvency arrangement.
The judge found that the IVA complied with Northern Ireland law, was final, had been properly notified to creditors and did not conflict with Irish public policy or equivalent personal insolvency principles. He also found no unfairness, noting that creditors would receive nothing in a bankruptcy scenario.
The court therefore recognised and enforced the IVA in Ireland, specifically in relation to Bank of Ireland's £150,000 claim. Enforcement of that debt was stayed while the IVA terms are fulfilled. The bank was given liberty to return to court if it wished to raise any issue.