Vive la différence: English High Court refused to grant an interim anti-suit injunction in support of ICC arbitration proceedings seated in Paris given the unavailability of such remedy in France

In a recent judgment of the English Commercial Court in SQD v QYP (Rev1) [2023] EWHC 2145 (Comm), the Court refused to grant an interim anti-suit injunction ("ASI") and an anti-enforcement injunction ("AEI") in support of arbitration proceedings seated in Paris. Whilst English Courts are ready and willing to support arbitration proceedings within the jurisdiction, and where appropriate also outside the jurisdiction, however, as was the case here, there may be exceptional circumstances militating against the granting of such relief, for example where there exists a fundamental objection to ASIs at the seat of arbitration.

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