The Ontario Court of Appeal (“The Court”) has overturned the decision of an application judge who refused to set aside an arbitral award despite a finding of a reasonable apprehension of bias…
The judgment of the Singapore International Commercial Court (the “Court”) in DJO v DJP and others [2024] SGHC(I) 24 (“DJO”) provides helpful guidance on when an award may be set aside for breach of…
In July and August 2024, the Court of Appeal for Ontario (CA) and the Ontario Superior Court of Justice (SCJ) have addressed critical questions concerning the jurisdiction of arbitration tribunals…
Large arbitral awards have generally given rise to multi-jurisdictional post-award litigation (see Yukos). The Deutsche Telekom v India saga is a similar instance, with the Republic of India (“India”…
A recent decision, Nigeria vs P&ID, issued by the English High Court of Justice, has drawn significant global public attention. This decision is notable for several reasons. It is rare for English…
In 2004, Chile enacted Law No. 19.971 on International Commercial Arbitration (“LACI”) based on the UNCITRAL Model Law of 1985 (“Model Law”). This note describes, without assessing its merits, how…
Generally, by virtue of the principle of territoriality, the national courts of a State have jurisdiction only over persons and acts committed within the territory. In this context, the national…
On 12 May 2023, the Santiago Court of Appeals (“Court”) denied EP Petroecuador’s (“Petroecuador”) (Ecuador national oil company) petition to set aside a US$63 million international commercial…
A recent decision of the Hanoi People’s Court, Decision No. 12/2023/QD-PPT dated 4 July 2023 (“Decision 12”), held that a power-of-attorney (“POA”) signed outside of Vietnam and authorizing the…
