§ 8.01-195.No judgment to be paid without special appropriation.

Section 8.01-195 closes Article 18 with a limit that shapes every claim decided under it. Winning a judgment against the Commonwealth in circuit court, following the procedure Sections 8.01-192 through 8.01-194 lay out, does not by itself guarantee payment. Unless some other law expressly provides otherwise, no judgment against the Commonwealth will be paid without a special appropriation made for it by the General Assembly.

That requirement reflects a basic feature of suing a sovereign government: the courts can adjudicate whether the Commonwealth owes money, but the actual disbursement of state funds is a legislative act. A successful claimant walks away with a judgment establishing the debt, but collecting on it depends on the General Assembly separately appropriating the money to pay it, unless another statute has already made that appropriation unnecessary.