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ArbitrationLMAA Award not Recognised in Russia and Lugovoy Law is not the Reason
“GA ARB IN UK ENGLISH LAW TO BE APPLY BE” – means only arbitration on GA, not on demurrage disputes The maritime industry loves abbreviations. This dates back to the time when charter parties were fixed by telex and every letter cost money. So, the arbitration clause in question read as follows: “GA ARB IN […]
- Maritime Industry Sanctions
Under ExxonMobil VOY2005 sanctions clause, a real risk of sanction liability is sufficient to refuse loading of cargo
Summary In a recent decision published on 22 May 2026 “Tonzip Maritime (Singapore) Pte Ltd v 2 Rivers Pte Ltd” the Court of Appeal of England and Wales, Civil Division [2026] EWCA Civ 641 – case no. CA-2025-002537, has allowed the appeal of the owners of the MV CATALAN SEA in a dispute arising from […]
Arbitration Recognition of foreign decisionsAIFC Court at a crossroads: Naftogaz v Gazprom, Posco v National Centre, and the limits of recognition jurisdiction
In our earlier analysis, “Clash of jurisdictions – AIFC Court recognises an ICC award despite opposing Russian anti-arbitration injunction”, we discussed the AIFC Court’s 15 May 2026 decision in National Joint Stock Company “Naftogaz of Ukraine” JSC v Gazprom PJSC, Case No. AIFC-C/CFI/2026/0002. The case was remarkable not only because of the size of the […]
ArbitrationBavarian Highest Regional Court: No Arbitration Agreement Established Where Bilingual Contract Versions Diverge
BayObLG, order of 16 June 2026 – 101 Sch 171/25 e In an order of 16 June 2026, the Bavarian Highest Regional Court (Bayerisches Oberstes Landesgericht, BayObLG) held that a dispute between two German companies was not subject to arbitration, despite an arbitral tribunal’s prior interim decision affirming its own jurisdiction. The Court found that […]
ArbitrationBombay High Court Refuses Interim Measures Based On Lugovoy Judgement
Background and Procedural Posture On 8 June 2026, the High Court of Bombay (Ordinary Original Civil Jurisdiction, Commercial Division) decided Interim Application No. 569 of 2026 in Commercial Suit No. 6 of 2026 between Limited Liability Company “EuroChem North‑West‑2” (Russia) and Tecnimont S.p.A. (Italy). EuroChem relies on a judgment of the Moscow Commercial Court dated 5 December […]
Recognition of foreign decisionsRecognition of Austrian Cost Orders in Russian Insolvency Proceedings – Arbitrazh Court of Kalmykia, 21 April 2026 (A22‑1431/2016)
1. Introduction On 21 April 2026, the Arbitrazh Court of the Republic of Kalmykia ruled on the recognition and enforcement in Russia of a cost decision issued by the Regional Court of Innsbruck (Landesgericht Innsbruck, Austria) in favour of a Russian creditor, Elena Nikolaevna Baturina, against a Russian debtor, Viktor Nikolaevich Baturin, who was already […]
Arbitration Recognition of foreign decisionsSuspicion of control by sanctioned entities is not enough to avoid payment under coal supply contract – says ICC Tribunal – Moscow Arbitrage court grants enforcement
Introduction On 15 May 2026, the Moscow Arbitrazh Court rendered a decision in case No. А40-332538/25-68-2153, granting enforcement of an arbitral award rendered on 18 September 2025 by a Tribunal under the auspices of the International Court of Arbitration of the International Chamber of Commerce (ICC) in Paris (Case No. 27933/ELU). The decision addresses the enforcement of […]
