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Recognition & Enforcement

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1. Summary Could permission to set aside the English court’s permission to enforce a Swedish arbitral award allegedly obtained by fraud be granted in circumstances where the Swedish courts had dismissed an application to set aside the award? In Anatolie Stati and others v Republic of Kazakhstan [2017] EWHC 1348 (Comm), the English court held that the Respondent had established a sufficient case that an arbitral award had been obtained by the fraud of the…

The United States District Court for the Southern District of Florida, in Inversiones y Procesadora Tropical INPROTSA, S.A. v. Del Monte Int’l GmbH, Case No. 16-24275-CIV (S.D. Fla. May 1, 2017), recently confirmed an ICC award in favor of Del Monte International GmbH against Costa Rican pineapple grower Inversiones y Procesadora Tropical INPROTSA, S.A. Del Monte and INPROTSA were parties to an exclusive Pineapple Sales Agreement that called for ICC arbitration in the event of…

In 1999, Enron Nigeria Power Holding, Ltd (“ENPH”) entered into a power purchase agreement (“PPA”) with Nigeria, Lagos State, and the National Electric Power Authority of Nigeria. The PPA envisioned construction of electricity generation units in three phases, however, shortly after its execution, the PPA was deemed invalid by the Nigerian Attorney General and had to be amended. Phases I and III of the PPA were sold to another entity, while ENPH retained its Phase…

Canada has long been an arbitration-friendly jurisdiction and was the first state to adopt the 1985 UNCITRAL Model Law on International Commercial Arbitration (“Model Law”). On March 22, 2017, the Canadian province of Ontario updated its international arbitration regime to adopt the 2006 amendments to the Model Law. The Ontario International Commercial Arbitration Act, 2017, SO 2017, c 2 (the “ICAA”) replaces the former Ontario International Commercial Arbitration Act, RSO 1990, c I.9 (the “Former…