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Going International: The SICC in Frontier Holdings
By Sanjitha Ravi, Jindal Global Law School, OP Jindal Global University, Sonipat, India
The Singapore International Commercial Court (“SICC”) in Frontier Holdings Ltd v. Petroleum Exploration (Pvt) Ltd overturned a jurisdictional ruling by an International Chamber of Commerce (“ICC”) arbitral tribunal, holding that the tribunal did, in fact, have jurisdiction to hear the dispute. The SICC’s decision focused on interpreting the arbitration provisions in the Petroleum Concession Agreements (“PCAs”) and Joint Operating Agreements (“JOAs”), which had created ambiguity regarding whether disputes between foreign parties, i.e., Foreign Working Interest Owners (“FWIOs”), and Pakistan parties, i.e., Pakistani Working Interest Owners (“PWIOs”), were subject to international arbitration. The arbitral tribunal, by majority, had concluded the PCAs restricted ICC arbitration to disputes between FWIOs inter se or between FWIOs and the President of Pakistan, thereby excluding disputes between FWIOs and PWIOs. The SICC rejected this reasoning and concluded that the provisions should be applied with necessary modifications to fit the JOAs’ context by conducting an in-depth construction of the dispute resolution provisions of the different agreements involved. The court found that a reasonable interpretation of these provisions indicated an intention to submit FWIO-PWIO disputes to ICC arbitration rather than Pakistani domestic arbitration. Read more
Enforcing Foreign Judgments in Egypt: A Critical Examination of Two Recent Egyptian Supreme Court Cases
I. Introduction
The recognition and enforcement of foreign judgments in the MENA region can sometimes be challenging, as it often involves navigating complex legal frameworks (domestic law v. conventions). In addition, case law in this field has encountered difficulties in articulating the applicable guiding principles and is sometimes ambiguous, inconsistent, or even contradictory. Two recent decisions rendered by the Egyptian Supreme Court highlight this issue, alhoutgh – it must be admitted – the Court did provide some welcome clarifications. In any event, the cases reported here highlight some key issues in the recognition and enforcement of foreign judgment and offer valuable insights into the evolving landscape of this area of law in Egypt.
Toothless vs. Shark-Teeth: How Anti-Suit Injunctions and Anti-Anti-Suit Orders Collide in the UniCredit Saga
by Faidon Varesis, University of Cambridge
Background
The dispute in the UniCredit v. RusChem saga arose from bonds issued by UniCredit to guarantee performance under contracts for Russian construction projects, where RusChem, after terminating the contracts due to EU sanctions, initiated Russian proceedings for payment in breach of an English-law governed arbitration agreement that mandates resolution in Paris under ICC rules.
UniCredit sought an anti-suit injunction in the UK to stop these Russian proceedings, arguing that the arbitration clause must be enforced under English law. Teare J at first instance held that the English court lacked jurisdiction—finding that the arbitration agreements were governed by French substantive rules and that England was not the appropriate forum—whereas the Court of Appeal reversed this decision by granting a final anti-suit injunction requiring RCA to terminate its Russian proceedings.
News
ZVglRWiss – Zeitschrift für Vergleichende Rechtswissenschaft 3/2025
ZVglRWiss – Zeitschrift für Vergleichende Rechtswissenschaft 3/2025
A new issue of ZVglRWiss – Zeitschrift für Vergleichende Rechtswissenschaft is now available and includes contributions on EU private law, comparative law, private international law, and individual European private law regimes.
The full table of content can be accessed here.
The EAPIL Winter School 2026: Values in Private International Law
As has become tradition, the European Association of Private International Law (EAPIL) will be hosting a Winter School in Como, from 2 to 6 February 2026. The general topic of the upcoming edition is Values in Private International Law.
The teaching staff will consist of Laura Carpaneto (University of Genoa), Javier Carrascosa González (University of Murcia), Maria Asunción Cebrian Salvat (University of Murcia), Gilles Cuniberti (EAPIL President, University of Luxembourg), Sara De Vido (Ca’ Foscari University of Venice), Stefano Dominelli (University of Genova), Cristina González Beilfuss (University of Barcelona), Thomas Kadner Graziano (University of Geneva), Eva Maria Kieninger (University of Würzburg), Silvia Marino (University of Insubria and coordinator of the Winter School), Johan Meeusen (University of Antwerp), Nadia Rusinova (The Hague University, Attorney at law), Veronica Ruiz Abou-Nigm (University of Edinburgh), Erik Sinander (Stockholm University), Sara Tonolo (University of Padua), Geert van Calster (KU Leuven), Hans van Loon (HCCH Former Secretary General), and Anna Wysocka-Bar (Jagiellonian University in Kraków).
The University of Insubria will host the 2026 edition, as it did in 2024 and 2025 (see here and here), in cooperation with University of Murcia and the Jagiellonian University in Kraków.
Those interested in attending the Winter School must apply by 20 January 2026 by completing the online form available here.
More information is available here.
New Volume of the Japan Commercial Arbitration Journal – Vol. 6 [2025]
The Japan Commercial Arbitration Association (JCAA), one of the oldest international arbitration institutions in the world founded in 1950, has published the 6th Volume of its annual journal on commercial arbitration: Japan Commercial Arbitration Journal.
The journal features articles on international commercial arbitration, mediation, and litigation related to Japan. These articles are authored by prominent scholars and experienced practitioners who are well-versed in the resolution and prevention of international commercial disputes.
The Japan Commercial Arbitration Journal is particularly valuable for non-Japanese readers, including foreign researchers and practitioners, as it provides insights into Japan’s approach to international dispute resolution. By offering comprehensive analysis and updates on arbitration, mediation and litigation practices in Japan, the journal helps bridge the knowledge gap for those working in international commercial law. Access to this information is essential for professionals seeking to understand the nuances of Japanese legal procedures and effectively engage with Japan in cross-border commercial matters. Read more