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Arbitration Maritime IndustryThe Prestige Dispute: UK Supreme Court Clarifies Remedies for Breach of Arbitration Agreements by Third Parties
I. Introduction On 28 October 2026, the UK Supreme Court delivered its unanimous judgment in The Kingdom of Spain and another v The London Steam-Ship Owners’ Mutual Insurance Association Limited (No 2) [2026] UKSC 36, addressing the application of the conditional benefit principle to arbitration agreements and the remedies available when third parties disregard their […]
Arbitration Investment Arbitration Recognition of foreign decisionsEnforcement of ICSID Awards and State Immunity: Singapore Court of Appeal Rules Against Spain
I. Introduction In its recent judgment in Kingdom of Spain v NextEra Energy Global Holdings BV and another [2026] SGCA 43, the Singapore Court of Appeal addressed the relationship between sovereign immunity and the recognition and enforcement of arbitral awards rendered under the Convention on the Settlement of Investment Disputes between States and Nationals of […]
Arbitration Maritime Industry Recognition of foreign decisionsAnti-Suit Injunctions and Parallel Proceedings: Singapore Court Restrains Litigation in China
In its recent decision in Xu Xiangrong v Fu Xianwei [2026] SGHC(I) 23, the Singapore International Commercial Court examined the circumstances in which parallel foreign proceedings may be restrained through an anti-suit injunction.
- Arbitration Maritime Industry Shipping and Transportation Law
Forged Charterparty Documents and Arbitration Agreements: Singapore High Court Sets Aside Demurrage Award
In its recent decision in DZD v DZE [2026] SGHC 199, the Singapore High Court examined whether a forged charterparty and the subsequent payment of freight could establish a valid arbitration agreement. The judgment highlights the fundamental importance of contractual consent in international arbitration and provides valuable guidance on the legal consequences of forged shipping […]
- Uncategorized
Art. 31 CMR, German Jurisdiction and Lithuanian Law: When Forum Selection Fails but Choice-of-Law Prevails
The recent judgment of the District Court Groß-Gerau offers an instructive illustration of the complex internaction between the Convention on the Contract for the International Carriage of Goods by Road (CMR), the Brussels I Regulation and the Rome I Regulation in cross-border transport disputes. I. Introduction Cross-border road transport disputes within the EU frequently raise […]
- Arbitration
Sanctions vs. Enforcement: Limits and Lessons from the Swiss Federal Tribunal
This decision provides essential guidance on the interaction between sanctions law and private enforcement mechanisms in Switzerland.For this, the Federal Tribunal establishes three key principles: This judgment is highly significant, as it forms part of a body of international case law recognizing the relevant claim in itself, although payment of that claim is not currently […]