Not always.
Even if both spouses have been living outside Russia for a long time, Russian courts may in some cases consider notification to the last known address in Russia to be sufficient.
However, in international family disputes, the issue of notification is often far more complex than it initially appears.
From the perspective of Russian procedural law, service to a Russian address may sometimes be accepted as proper notification. But if the judgment later needs to be:
— recognized abroad;
— used in foreign proceedings;
— or enforced in another country,
a foreign court may assess the notification issue differently.
For many foreign jurisdictions, it is critically important whether the party was actually informed about the proceedings and had a genuine opportunity to participate in the case.
Therefore, if the Russian court knew that one spouse was in fact living abroad, but notification was sent only to an old Russian address, this may create serious risks when seeking recognition of the Russian judgment in another country.
This is why an international divorce is rarely only about obtaining a divorce decree itself. From the very beginning, it is often necessary to consider:
— international service of process;
— future recognition of the judgment abroad;
— possible parallel proceedings in different countries;
— and the overall cross-border litigation strategy.