Examining the Nuances of Contrasting Dispute Resolution Mechanisms Within the Same Agreement
BACKGROUND1. This judgment of the King’s Bench Division concerns an application by Bugsby Property LLC (“Bugsby”) and Bugsby Investments Limited (“BIL”) (collectively, “Claimants”) seeking...
DIFC courts confirm their protective jurisdiction to grant freestanding freezing relief
INTRODUCTION1. The DIFC Court of Appeal (“DIFC CA”) in Sandra Holding Ltd. v. Fawzi Musaed Al Salehi (“Sandra Holding”) caused quite a stir in...
Singapore High Court discusses the limits of enforcement under the New York Convention
INTRODUCTION1.The enforcement of foreign arbitral awards is a cornerstone of international commercial arbitration. It is governed by the New York Convention, which ensures the...
England and Wales: a bankruptcy petition cannot be presented on the basis of an unrecognised foreign judgment
I. INTRODUCTION
The UK Court of Appeal, in Servis-Terminal LLC v. Valeriy Ernestovich Drelle (“Drelle CA”), has overturned the English High Court’s decision in Valeriy...
England and Wales: a bankruptcy petition cannot be presented on the basis of an unrecognised foreign judgment
I. INTRODUCTIONThe UK Court of Appeal, in Servis-Terminal LLC v. Valeriy Ernestovich Drelle (“Drelle CA”), has overturned the English High Court’s decision in Valeriy...
