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CC/Devas (Mauritius) Ltd & Ors v The Republic of India (Re Consequential Matters) [2025] EWHC 1189 (Comm) (16 May 2025)

Source: Open mirrored case · Original bailii.org

Sanctions — Geo ✓

Executive Summary

  • The High Court of England and Wales ruled on consequential matters following its April 2025 judgment enforcing arbitration awards against India.
  • Central issue: whether India’s ratification of the New York Convention (NYC) constitutes prior written consent to English court jurisdiction under s.2(2) of the State Immunity Act 1978 (SIA).
  • Court found India did **not** submit to jurisdiction by ratifying the NYC alone.
  • Permission to appeal granted due to wider implications for state immunity jurisprudence.
  • Costs awarded to India for the s.2 question hearing, with debate over timing and set-off against arbitration awards.
  • The case involves complex interplay between arbitration enforcement, state immunity, and procedural costs.

Sanctions Highlights

  • — No sanctions implications identified in the judgment or related matters.

Emerging Risks

  • Potential for protracted litigation due to India’s invocation of state immunity and ongoing challenges to arbitration awards.
  • Uncertainty over enforcement of arbitration awards against sovereign states when ratification of international conventions is contested.
  • Possible delays and increased legal costs arising from appeals and cross-jurisdictional disputes.
  • Disputed validity of assignment of claims to later claimants (4th to 6th) may complicate enforcement and recovery.

Geopolitical Impact

  • Case highlights tensions between India and foreign investors/creditors, impacting UK-India legal and commercial relations.
  • UK courts’ role in adjudicating disputes involving Indian state immunity may influence bilateral investment climate.
  • Reference to related UK Supreme Court pending appeal in a similar ICSID Convention case involving Spain signals broader Commonwealth and international legal ramifications.
  • US and UK law firms involved underscore transatlantic interest and expertise in sovereign arbitration enforcement.

Economic Intelligence

  • Arbitration awards upheld in multiple jurisdictions (notably the Netherlands) reinforce creditor confidence outside India.
  • India faces significant potential liabilities, with costs claimed by India exceeding £580,000 for this stage alone.
  • Enforcement challenges may affect foreign direct investment perceptions in India, particularly in telecom and infrastructure sectors.
  • The dispute involves complex financial interests of multiple claimants, including US and Mauritius-based entities.

Strategic Recommendations

  • Monitor appellate developments closely, especially the Supreme Court’s ruling on ICSID and NYC ratification issues.
  • Assess impact of state immunity interpretations on enforcement strategies for arbitration awards involving sovereign states.
  • Engage with legal counsel to prepare for potential cost liabilities and explore set-off mechanisms against awards.
  • Consider geopolitical sensitivities in litigation strategy, balancing enforcement efforts with diplomatic and investment relations.
  • Track related cases in the Netherlands and other jurisdictions for precedent and enforcement trends.

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**Source Notes:** *Sanctions Intelligence Digest* — [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1189.html](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1189.html)

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