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 […]
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 […]
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 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. […]
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 […]
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 […]
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 […]