Can an Israeli succession order be resealed in England, or do I need a fresh grant of probate?

Older English probate practitioners sometimes remember that grants from Palestine could once be resealed in London, and they are not misremembering. The Colonial Probates Act 1927 extended the 1892 Act to mandated territories, and Mandatory Palestine was one. That door closed in 1948, and the schedule as it stands today does not carry the State of Israel forward.

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Detailed Answer

An Israeli succession order (צו ירושה) or will execution order (צו קיום צוואה) is granted by the Inheritance Registrar (Rasham HaYerushot) at the Ministry of Justice under Section 66 of the Succession Law 1965, after the Section 67 publication and a period of not less than two weeks for objections. It is a public document, so the apostille under the Hague Convention 1961 comes from the Israeli Ministry of Foreign Affairs, not from a Magistrates' Court, which handles notarial signatures instead. That apostille authenticates the order. What it does not do is give the order any operative force over a Barclays account in Manchester or a title registered at HM Land Registry. Authentication and legal effect are different questions, and English registries answer the second one strictly.

Where there are English or Welsh assets, the route is a fresh grant under rule 30 of the Non-Contentious Probate Rules 1987, which allows a district judge or registrar to issue a grant, limited as directed, either to the person entrusted with administration by the court of the deceased's domicile or, failing that, to the person beneficially entitled under the law of that domicile. Rule 19 governs how you prove Israeli law to the registry: an affidavit or witness statement from someone the registrar accepts as suitably qualified, or a certificate by a notary practising in Israel. In practice this means an Israeli lawyer swears to what the succession order means and who takes what, and the English solicitor annexes it to the PA1P or PA1A. Nobody in the family needs to appear. Everything moves by courier and by e-mail between the Israeli lawyer and the English firm, though the physical apostilled order should be sent by tracked post because registries still want to see the seal. Expect the Israeli order to be in Hebrew and to need a translation. An Israeli notarial translation is the sensible choice, since the same bundle usually has to satisfy an Israeli bank as well. If the estate is being administered from London, the sequencing questions are set out in more detail in our guide for UK executors administering an Israeli estate.

In Practice: The Inheritance Registrar issues the order under Section 66 of the Succession Law 1965 for NIS 597 on paper or NIS 507 online, plus a NIS 66 publication fee, and an uncontested file at the Tel Aviv or Jerusalem Registrar closes in three to six months. The Ministry of Foreign Affairs apostille costs about NIS 41 and is usually issued over the counter in Jerusalem the same day. On the English side, HMCTS raised the probate application fee from GBP 300 to GBP 526 on 13 July 2026 for estates above GBP 5,000, and a rule 30 application with foreign law evidence typically takes 8 to 16 weeks from lodgement.

When to Consult a Lawyer

• The deceased was domiciled in Israel but held a UK bank account, ISA or shareholding. Rule 30 grants are limited grants, and the limitation wording has to match what the Israeli order actually says, or the bank will reject it after you have already paid the GBP 526.
• Inheritance tax is in play. Since 6 April 2025 UK inheritance tax follows long-term residence rather than domicile, so worldwide assets fall in where the deceased was UK resident for at least 10 of the previous 20 tax years, with a tail of up to 10 years after leaving. Israeli assets then go on IHT400 schedule IHT417, and because Israel has levied no estate duty since 1981 there is no foreign credit to offset the charge.
• The deceased left a will made in England. Section 137 of the Succession Law 1965 refers succession to the law of the domicile at death, subject to Sections 138 to 140, so an English-domiciled testator with a Tel Aviv apartment can produce a division that neither the English will nor Israeli intestacy alone would predict.

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Speak With an Israeli Attorney

We obtain the succession order, arrange the Ministry of Foreign Affairs apostille and the notarial translation, and provide the rule 19 affidavit of Israeli law your English solicitor needs to file with the rule 30 application.

Contact us for a confidential initial consultation.