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Maritime Industry Recognition of foreign decisionsCyprus court decision not recognised in Russia
Since 1984, Cyprus was one of the few EU countries to have concluded a mutual legal assistance agreement with Russia in civil and criminal matters, under which the two countries undertook to recognise the decisions of each other’s courts (Art. 23). However, current practice is such that this provision is no longer applied. Decisions by […]
- Recognition of foreign decisions
Is there or is there no reciprocity for the recognition of judgements between Russia and Germany?
A while ago we had reported on a decision of the Arbitrazh Court in St. Petersburg which had recognised a German court decision from Stuttgart on the basis of reciprocity – see here: Is there suddenly reciprocity regarding recognition of commercial judgements between Germany and Russia? – Koch Boës – Rechtsanwälte. Not unawaited, this decision […]
- Recognition of foreign decisions
Jurisdiction Clauses Can Close the Door – Lessons from a German-Russian Dispute
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 […]
- Recognition of foreign decisions
Reciprocity Between Germany and Russia: Russian Court Reverses Recognition of German 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 […]
Recognition of foreign decisionsIs there suddenly reciprocity regarding recognition of commercial judgements 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.
Arbitration Recognition of foreign decisionsAnother case of “jurisdictional ping-pong” aka Russian Court Decision denies – again – recognition and enforcement of arbitral award
Mike Ackerman via Unsplash 1. Introduction 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 […]
Arbitration Recognition of foreign decisionsArbitral award not recognised because arbitrators came from “unfriendly countries”
Darla Hueske via Unsplash Introduction On July 26. 2024, another judgment of the Supreme Court of the Russian Federation (Case А45-19015/2023, judgment No. 304-ЭС24-2799) made headlines regarding a legal dispute between a German claimant and Russian defendant. The underlying legal dispute was preceded by an arbitration award by an arbitration tribunal in London applying the FOSFA […]
