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 […]
Category: Arbitration
Bavarian 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 […]
Bombay 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 […]
Suspicion of control by sanctioned entities is not enough to avoid payment under coal supply contract – says ICC Tribunal – Moscow Arbitrage court grants enforcement
Russia Enforces ICC Arbitral Award Despite Sanctions Objections
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 […]
Clash of jurisdictions – AIFC Court recognises an ICC award despite opposing Russian anti-arbitration injunction
Will Kazakhstan side with the New York Convention or recognise a Lugovoy judgement? On 15 May 2026, the Court of First Instance of the Astana International Financial Centre (“AIFC Court”) issued a judgment recognising and enforcing a USD 1.37 billion ICC arbitral award obtained by Naftogaz against Gazprom. The award itself had been rendered in […]
Enforcement against Russian Assets on Spitsbergen: The Yukos Capital v. Russian Federation Decision of Nord‑Troms og Senja District Court
I. Introduction On 20 December 2024, the Nord‑Troms og Senja District Court in Norway rendered a decision on the enforcement of a foreign arbitral award against assets of the Russian Federation located on Svalbard (Spitsbergen) (case no. 24‑163368TVA‑TNTS/TTRM). The case concerns Yukos Capital Limited’s attempt to secure and enforce a multi‑billion‑dollar UNCITRAL arbitration award arising […]
Russian Federation vs. Wintershall (almost) reloaded
Anti Arbitration injunction against Austrian claimant granted, but injunctions against arbitrators withdrawn.
On 3 April 2026, the Arbitrazh Court of the Kaluga Region issued an anti-arbitration injunction in case No. A23-9385/2025 involving JSC “Kaluga Plant Remputmash” (“RPM”) and Austrian manufacturer L. Maschinenfabrik GmbH. In application of the notorious “Lugovoy-Law” (art. 248.1 and 248.2 of the APC), the court prohibited the Austrian company from continuing or supporting arbitration […]