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Enforcement of English Judgments in Russia: Reciprocity

Unlike the New York Convention 1958, which provides a straightforward procedure for enforcement of arbitration awards in another signatory state, there is no single unifying international treaty or convention when it comes to court judgements. Enforcement of foreign judgments is often covered by bilateral or multilateral treaties which vary from country to country. However many […]

Moscow Arbitrazh Court recognised and enforced Belgian state court decision.

With a judgement of 14.12.2020 (court case number A40-111764/20) the Arbitrazh Court of Moscow recognised and declared enforceable a decision of an Antwerp court. The Moscow Arbitrazh Court referred to Art. 15 para 4 of the Russian Constitution according to which the recognised principles and norms of international law are an integral part of the […]

German Supreme Court has its own „Enka v. Chubb“: How Germany and the UK determine the law governing the arbitration agreement

In most cases, the question which law applies to the arbitration agreement is rather academic, but in some rare cases, this question can decide about the validity of the arbitration clause or even the extension to non-signatories. After the UK Supreme Court decided on the famous „Enka v. Chubb“ matter, the German Supreme Court now […]

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