On 10 October 2013, the Supreme Court of Lithuania
made a preliminary reference to the Court of Justice of the European Union
(ECJ) of the question whether an EU member state can refuse to enforce an
arbitral award that contains an anti-suit injunction because it is inconsistent
with the Brussels Regulation. On 4 December 2014, Advocate General Wathelet of
the ECJ gave his opinion that the Brussels Regulation must be interpreted as
not requiring an EU member state court to refuse to recognise and enforce an anti-suit
injunction issued by an arbitral tribunal. In his view, recognition and
enforcement fell exclusively within the scope of the New York Convention
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