The Paris Court of Appeal ruled yesterday on the action introduced by the Government of Pakistan to set aside the award which had ordered it to pay over USD 20 million to Dallah.
The Court found that the arbitral tribunal had been right to retain jurisdiction in this case, and dismissed the action of Pakistan.
We had already reported on the English decisions which had denied enforcement of this award in the United Kingdom. Quite remarkably, the English Court of appeal and then the UK Supreme court held that, under French law, the arbitral tribunal did not have jurisdiction.
It seems that French judges were unimpressed by the lectures that Lord Collins and Lord Mance gave on the French law of arbitration at this occasion.
Someone must now find a solution to this mess: Twickenham?
More on the reasons of the French court soon.