International news (Arbflash, October 2010)

Bombay High Court issues an injunction against arbitration proceedings

On 17 September the Bombay High Court issued an anti-arbitration injunction in the case of MSM Satellite (Singapore) Pte Ltd.-v- World Sport Group (Mauritius) Limited. The injunction prevents a contractual dispute from being referred to arbitration despite the presence of an arbitration clause in the contract. The court gave three reasons for its decision. First, fraud had been alleged against one of the parties. Second, the contractual agreement between the parties, regarding the television rights to the Indian Premier League cricket tournament, was held to be against Indian public policy. Third, the Board of Control for Cricket India, a party whose attendance would be required at an arbitration, was not a signatory to the arbitration agreement. It is likely that an appeal against the injunction will go to the Supreme Court.

LCIA India receives its first case

The London Court of International Arbitration India received its first referral in May of this year, only a month after it published its arbitration rules. It is not clear as to whether it is administering this case itself or whether it is acting as appointing authority at the request of another arbitral institution, where the parties cannot agree on the appointment of arbitrators. Other referrals have been rumoured but in these cases the parties would appear to have settled.

India to reform commercial dispute resolution system

As part of a widespread reform, the Indian Government is proposing to amend the Arbitration and Conciliation Act 1996. The amendment being considered is the introduction of a provision into the Act under which, for all commercial contracts of a value over Rs.5 crore (approximately US$1m), an arbitration agreement will be incorporated as an implied term. Such a provision would clearly see a huge number of contract disputes dealt with by arbitration rather than the courts. It is worth noting, however, that at the moment parties would be given the opportunity to opt out of such an arbitration agreement.

Russian court refuses to enforce ICC award

The Commercial Court of Tomsk has refused to enforce an award of over US$117m by the ICC on an arbitration between Tomskneft and Yukos Capital, two of the former subsidiaries of Yukos Oil Company. The award for recovery of debt arising from loans made from Yukos Capital to Tomskneft was declined on public policy grounds, with the court finding that the dispute was a "sham from the outset". The court noted that Tomskneft had funded the loans to itself through transfer pricings within the Yukos group. The court also refused enforcement on another ground, that Tomskneft had not been given due notice at several stages of the arbitral proceedings.

Australian International Disputes Centre opens in Sydney

A new international dispute centre opened at the start of August in Sydney. The Australian International Dispute Centre will look to compete with Hong Kong and Singapore as an Asia-Pacific arbitration destination. The opening comes shortly after a series of amendments to Australian arbitration law designed to improve effectiveness, efficiency and affordability of international arbitration on home shores.

KLRCA adopts UNCITRAL Arbitration Rules 2010

The Kuala Lumpur Regional Centre for Arbitration (KLRCA) has adopted the new UNCITRAL Arbitration Rules 2010, becoming the first centre to adopt the revised rules. The KLRCA was established in 1978 under the auspices of the Asian-African Legal Consultative Organization (AALCO), an inter-governmental organisation comprising 47 governments of the Asian and African region, in co-operation with the government of Malaysia.

 

Please click on the links below for the other articles in the October 2010 Arbflash:

 

Contact

Ronnie King
T: +44 (0)20 7859 1565
E: ronnie.king@ashurst.com

 

This publication is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Readers should take legal advice before applying the information contained in this publication to specific issues or transactions.