UK Ruling Evinces Conflict In Int'l Award Enforcement

By Randa Adra, John Laird and Edward Norman (November 9, 2021, 12:42 PM EST) -- In Kabab-Ji SAL v. Kout Food Group, a U.K. Supreme Court bench unanimously dismissed an appeal by Lebanese restaurant chain Kabab-Ji and declined to enforce an International Chamber of Commerce award against Kuwait's Kout Food Group.[1]

The circumstances of the case revive a decade-old cautionary tale in Anglo-French judicial relations and the potential lack of consensus in the cross-border enforcement of international awards.

The judgment by Justice Nicholas Hamblen and Justice George Leggatt affirms principles from their majority judgment last year in Enka Insaat Ve Sanayi AS v. OOO Insurance Company Chubb.[2]

English courts will continue to apply English law principles...

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