article thumbnail

Anti-enforcement injunction granted by the New Zealand court

Conflict of Laws

For litigants embroiled in cross-border litigation, the anti-suit injunction has become a staple in the conflict of laws arsenal of common law courts. In fact, Kea had originally advanced a cause of action for abuse of process, claiming that the alleged fraud was an abuse of process of the Kentucky Court.

Court 52
article thumbnail

Dubai Courts on the Recognition of Foreign Judgments: “Recognition” or “Enforcement”? – that’s the Problem!

Conflict of Laws

The case The parties, in this case, are (1) A British Virgin Islands company (hereinafter ‘X1’) and its judicial liquidator (hereinafter ‘X2’, collectively “Xs”) and (2) four companies having considerable estates in Dubai (hereinafter ‘Y’). Weller et al. 1983-184ff). 375 of 23 May 2023 ). 208/2015 of 7 October 2015 ; DSC, Appeal No.

Court 52
article thumbnail

Application of Singapore’s new rules on service out of jurisdiction: Three Arrows Capital and NW Corp

Conflict of Laws

4] As Three Arrows illustrates though, old habits die hard and the limits of the ‘non-exhaustive’ nature of the jurisdictional gateways remains to be tested by litigants. 2] For step (a), the previous Order 11 gateways have been transcribed as a non-exhaustive list of factors. [3]

Court 67