Background
A Moscow court (Taganskyy District Court) issued a judgment against the respondent on April 19, 2021. The petitioner, Leonid Krasner, sought to enforce this Russian judgment in Israel. On March 24, 2026, Israel’s Central-Lod District Court ruled that the Russian judgment was enforceable in Israel subject to specified conditions, and ordered Krasner to pay 50,000 NIS in court costs.
Krasner filed a notice of appeal but requested an extension of the deadline to submit his full appellate brief. The original deadline was approaching, and he sought until September 15, 2026 to file. Krasner is currently subject to bankruptcy proceedings in Russia and faces multiple obstacles: he has not yet received a response to his request for legal aid in Israel; he speaks Hebrew only at a basic, daily level and is unfamiliar with Israeli law; and he is in the process of obtaining a foreign passport to travel to Israel, a procedure that could take several months. Additionally, enforcement of the district court judgment is automatically stayed for 60 days following submission of the judgment to the Russian trustee overseeing his bankruptcy.
The respondents opposed the extension, arguing that Krasner acted in bad faith, has substantial assets in Israel exceeding millions of NIS that are not subject to Russian bankruptcy proceedings, failed to provide supporting affidavits, and did not demonstrate the “special circumstances” required under Israeli civil procedure rules.
The Court’s Holding
The Supreme Court, sitting as an appellate court, granted the extension. The court held that an application for legal aid can constitute “special circumstances” justifying an extension of time to file an appeal under Civil Procedure Rules 176(b). The court noted that cases have recognized legal aid applications as potentially qualifying circumstances (citing Civil Application 3715/19, decided July 2, 2019).
The court further found that Krasner’s limited command of Hebrew and his lack of familiarity with Israeli legislation and case law constituted additional substantial difficulties in preparing an appellate brief without legal representation. The court noted that the petition was filed before the deadline expired, that Krasner has a right of appeal, and that the application was timely. Balancing these factors—along with the fact that the decision was being rendered relatively soon after the extension request—the court determined that the circumstances warranted leniency.
The Supreme Court extended the deadline to September 15, 2026, for Krasner to file his appellate brief. The court ordered that reference to this extension be noted at the beginning of the appellate filing, with a copy of this decision attached. Given the circumstances, no costs were awarded against the petitioner.
Key Takeaways
- Applications for legal aid, combined with other obstacles such as language barriers, can satisfy the “special circumstances” requirement for extending appellate deadlines under Israeli procedural rules.
- A litigant’s unfamiliarity with the foreign legal system and limited proficiency in the local language are recognized as valid grounds supporting extension requests.
- The timing of an extension request—filed before the deadline expires—weighs significantly in favor of granting it, particularly when combined with other legitimate difficulties.
- Israeli courts will not dismiss extension requests merely because an affidavit was not submitted in the current proceeding if the petitioner has already sworn statements in related proceedings.
Why It Matters
This decision clarifies that Israeli courts recognize practical barriers faced by pro se litigants and those unable to obtain timely legal representation. The holding is significant for foreign nationals involved in Israeli litigation who may lack fluency in Hebrew or familiarity with Israeli law. By endorsing language barriers and pending legal aid applications as “special circumstances,” the court signals a commitment to procedural fairness even when strict deadlines would otherwise bar participation.
The decision also reflects the court’s willingness to accommodate litigants facing concurrent legal proceedings in multiple jurisdictions, particularly when bankruptcy or insolvency proceedings in one country impose automatic stays or resource constraints affecting a litigant’s ability to participate fully in foreign proceedings. The court’s refusal to award costs further demonstrates deference to vulnerable litigants asserting their appellate rights, provided the extension is sought in timely fashion.