News

The Singapore International Commercial Court has dismissed the Russian Federation’s attempt to set aside an order granting leave (the “Leave Order”) to the former majority shareholders of OAO Yukos Oil Company (the “Claimants”) to enforce three arbitral awards amounting to more than US$63 billion (the “Final Awards”). The Russian Federation had contended that it is immune from the jurisdiction of the Singapore courts pursuant to the State Immunity Act, and that the “Arbitration” exception did not apply because it had not “agreed in writing” to submit the underlying dispute to Arbitration. The Claimants successfully argued that the Russian Federation is precluded from arguing that it had not agreed in writing to submit its dispute with the Claimants to arbitration, on the basis that the legal and factual issues which are determinative of that question are the subject of final and conclusive decisions on the merits by the Dutch seat courts, and accordingly give rise to transnational issue estoppel. The Singapore International Commercial Court will next hear the Parties on whether the Russian Federation is entitled to directions for filing of challenges against the enforcement of the Final Awards on the merits.

Our Deputy Head of the Commercial & Corporate Disputes Practice Wendy Lin, and Partners Jill Ann Koh, Andre Soh, Senior Associate Yap Zhan Ming, and Associates Wee Jong Xuan, Sean Koh and Zhan Xiangyun, successfully acted for the Claimants in defending against the Russian Federation’s attempt to set aside the Leave Order on the basis of State Immunity.

Click here to view a copy of the Singapore International Commercial Court’s Judgment in Hulley Enterprises Ltd and others v The Russian Federation [2025] SGHC(I) 19.