Jurisdiction(s):
United Kingdom

AEIs and AASIs to restrain extra-territorial enforcement of Russian judgments: English Commercial Court guidance, including ‘may’ jurisdiction clause held exclusive, in Google v Tsargrad [2025] EWHC 94 (Comm)

Published on: 29 January 2025

Published by a LexisNexis Dispute Resolution expert

Legal News

Article summary

Google LLC And Google Ireland Ltd v (1) Nao Tsargrad Media, (2) No Fond Pravoslavnogo Televideniya And (3) Ano Tv-Novosti) [2025] EWHC 94 (Comm)

What are the practical implications of this case?

This decision is the latest in a series arising from a Russian statute empowering Russian courts to claim exclusive jurisdiction over disputes involving sanctioned entities, despite any conflicting contractual dispute resolution clauses. It is therefore essential reading for anyone in a dispute with a Russian counterparty at any point in the lifecycle of proceedings.

Parties should think carefully about timing and litigation strategy, particularly whether to seek an anti-suit injunction and/or an AEI.

Even if such orders are not recognised or have limited effect in Russia, they can still be valuable in blocking or deterring enforcement efforts in other jurisdictions.
The judgment sets out core principles distilled from the authorities on the grant of AEIs, including the relevance of delay and the comity-based policy considerations that may influence the court’s discretion.

As a result, the ruling operates as a practical aide-memoire for those contemplating an AEI, offering a concise framework of the key points the court will weigh when deciding whether to grant such relief...

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