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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.
Recognition of foreign decisionsMoscow Court Enforces Chinese Judgment in Russia Upon Direct Filing
Introduction In a decision dated 10 September 2026, the Arbitrazh Court of the City of Moscow in Case No. A40-205251/25-19-1598 rendered an order on the recognition and enforcement in Russia of a judgment issued by the Nanhu District People’s Court of Jiaxing, Zhejiang Province, China. The Moscow court permitted the Chinese judgment creditor to apply […]
Arbitration Recognition of foreign decisions SanctionsAssignment of an ICC Award in Russia – the golden route to enforcement
Sverdlovsk court rejects sanctions, sham-transaction and tribunal-composition objections in a dispute over an assigned supply receivable and allows the enforcement of an assigned claim.
- Arbitration Recognition of foreign decisions
AIFC Court sets aside Naftogaz recognition order against Gazprom for lack of jurisdiction
Introduction In a decision dated 7 July 2026, the Court of First Instance of the Astana International Financial Centre in case number AIFC-C/CFI/2026/0002, National Joint Stock Company “Naftogaz of Ukraine” JSC v Gazprom PJSC, rendered a judgment on the AIFC Court’s jurisdiction to recognise and enforce a foreign-seated ICC arbitral award. Justice Lord Faulks KC […]
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 […]
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 […]
