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The Gibbs rule provides that the discharge of a debt may only properly be determined by the governing law of the debt. Subject to the modifying effect of legal instruments in the area of cross-border insolvency, an English court may apply this common law rule to hold that a foreign restructuring, which purports to discharge an English law governed debt (or a debt governed by a law other than the law of the foreign restructuring), does not in fact do so in England. Consequently, the court may allow a dissenting creditor to enforce the debt in England. The nature and extent of the Gibbs rule will therefore be of interest to distressed debt investors and their advisers and this note sets out some of the important issues to be considered.