Intra-EU investment arbitration: two EU Member States confirm the scope of the Achmea ruling

National courts continue to draw all the consequences of the Achmea ruling (CJEU, March 6, 2018, C-284/16) and its derivative case law (Komstroy, PL Holdings, etc.), reaffirming the incompatibility of arbitration clauses included in intra-EU bilateral investment treaties (BITs) with EU law. In Germany, the Federal Court refused to recognize an arbitral award handed down […]

Enforcement of arbitral awards and enforcement immunities: the French Supreme Court provides further clarification on proof of diplomatic use of seized state property

In a decision dated 12 June 2025, handed down in connection with the Commisimpex saga, the French Supreme Court clarified the rules governing evidence applicable when the debtor State invokes the diplomatic use of a real estate property subject to enforcement measures. The ruling clarifies the tricky relationship between protecting diplomatic missions and ensuring the […]

Independence and impartiality: the mere mention of a third party in the information sheet does not require the arbitrator to disclose his or her relationship with the third party

In a decision dated 7 May 2025, the French Supreme Court provided important clarification regarding the arbitrator’s duty of disclosure. The dispute involved the Ecuadorian company Seitur and the Dutch company CW Travel Holdings (CWT). In the ICC arbitration proceedings, the case information sheet mentioned a third party, Polimundo, among the “other entities involved”. Seitur […]