When entering into international contracts, parties often agree in advance which courts should resolve any disputes that may arise. While this approach offers predictability and legal certainty, it can also severely limit a party’s options. While it is a common approach to avoid foreign jurisdictions, one might learn that a decision from one’s “home” courts […]
Category: Recognition of foreign judgments
Russian Court issues injunction against Claimant, Arbitrators and Counsel in Energy Treaty dispute
Russia acts not only against foreign parties, but also against counsel and arbitrators
On 29 April 2025, the Moscow Arbitrazh Court (Case Number: А40-92702/25-56-674) granted a motion applied for by the General Prosecutor’s Office of the Russian Federation for interim relief, ordering the suspension of all arbitration procedures in the case of Wintershall Dea GmbH v. Russian Federation. The order applies until the court issues a final ruling […]
Reciprocity Between Germany and Russia: Russian Court Reverses Recognition of German Judgment
Russian Arbitrazh Court Reverses Recognition of German Commercial Judgment
On 1 April 2025, the Arbitrazh Court of the North-Western District (St. Petersburg) issued a landmark judgment in case no. A56-49800/2024, reversing an earlier decision that had recognized and enforced a German court ruling. The case, involving a claim by Viavi Solution Deutschland GmbH against Russian company OOO Vilkom SPb, has been sent back to […]
Is there suddenly reciprocity regarding recognition of commercial judgements between Germany and Russia?
Recognition and enforcement of state court decisions between Germany and Russia Recognition and enforcement of foreign judgements in Russia has been at the center of my professional interest for a long time now. The traditional approach under Russian law was that foreign court decisions were only recognised if there was a bi- or multilateral treaty. […]
Even an arbitration clause in favour of a seat in a ‘friendly’ country can be overturned by Russian courts.
Introduction On August 28, 2024, the Arbitrazh Court of Primorsky Kray in Russia issued a notable ruling in Case А51-7534/2024. The dispute involved a Russian plaintiff and an Irish defendant concerning the modification of a bareboat charter agreement for a vessel, as well as the recognition of ownership rights over that vessel. Background facts The […]
EU General Court confirms prohibition of rendering legal services to Russian legal entities and gives guidance regarding the exceptions
On October 2, 2024, the General Court of the European Union (Grand Chamber) delivered a significant ruling in Case T-797/22. The claim was filed by the Ordre néerlandais des avocats du barreau de Bruxelles (Belgium) and other applicants, supported by the Bundesrechtsanwaltskammer (Germany) and Ordre des avocats de Genève (Switzerland). The applicants challenged the legal […]
Another case of “jurisdictional ping-pong” aka Russian Court Decision denies – again – recognition and enforcement of arbitral award
Mike Ackerman via Unsplash In another case of “jurisdictional ping-pong” (see other cases discussed by us here and here), the Arbitrazh Court of the Sverdlovsk Region rendered a judgment on 16 August 2024 (case no. A60-24839/2024) in a legal dispute between a Polish claimant and a Russian defendant regarding the recognition and enforcement of an […]