Claims against States always raise complex issues. One issue that has arisen in a number of recent cases is effective service on a State. The Court of Appeal has now –  subject to any appeal to the Supreme Court – provided some clarity. But while the decision will assist those seeking enforcement in England of arbitration awards and certain foreign judgments made against foreign States, it may create issues for those wishing to bring fresh proceedings against a foreign State in the English Court, including for the enforcement of foreign judgments by way of fresh action.

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