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Diageo DV Ltd v Nio SRL [2025] EWHC 2109 (Comm) (06 August 2025)

Source: Open mirrored case · Original bailii.org

Sanctions — Geo ✓

Executive Summary

  • Diageo DV Ltd (Claimant) seeks an interim anti-suit injunction to restrain Nio S.R.L. (Defendant, in liquidation) from pursuing Italian court proceedings.
  • The dispute concerns withheld payment of €780,008 from a Deferred Payment under a Share Purchase Agreement (SPA) for shares in Niococktails s.r.l.
  • The SPA (governed by English law) contains an exclusive English jurisdiction clause (clause 24), while a related Deed of Transfer contains an exclusive Italian jurisdiction clause (Article 8).
  • The English court granted the interim injunction on 6 August 2025, prioritizing the SPA’s jurisdiction clause and preventing parallel litigation in Milan.

Sanctions Highlights

  • — No sanctions implications identified in the case.

Emerging Risks

  • Potential jurisdictional conflicts arising from overlapping jurisdiction clauses in related agreements (SPA vs. Deed of Transfer).
  • Risk of increased litigation costs and delays due to parallel proceedings in different jurisdictions.
  • Possible challenges to service validity under Italian law may complicate procedural timelines.
  • The Defendant’s liquidation status may affect enforcement and recovery prospects.

Geopolitical Impact

  • The case underscores the primacy of English courts in cross-border commercial disputes involving UK and EU entities post-Brexit.
  • Highlights ongoing legal friction points between UK and EU jurisdictions, here Italy, in enforcing jurisdiction agreements.
  • Reinforces the role of the 2005 Hague Convention on Choice of Court Agreements in supporting UK jurisdictional claims internationally.
  • Reflects broader US-linked commercial interests via Proximo Spirits Inc and McGregor Sports and Entertainment LLC, indicating transatlantic business ties.

Economic Intelligence

  • The dispute involves a significant sum withheld (€780,008) from a Deferred Payment of €1.25 million under the SPA.
  • The underlying commercial transaction relates to the alcoholic beverages sector, with Niococktails linked to promotional agreements involving US entities.
  • Settlement of prior claims by Niococktails with US parties for US$1 million impacts payment obligations and risk allocation.
  • The injunction protects Diageo’s financial interests and mitigates exposure to fragmented litigation costs.

Strategic Recommendations

  • Monitor developments in the anti-suit injunction proceedings, including any Defendant applications to set aside the order.
  • Prepare for potential enforcement challenges given Defendant’s liquidation and cross-jurisdictional complexities.
  • Advise clients on the importance of clear, consistent jurisdiction clauses in multi-agreement transactions to avoid parallel litigation.
  • Leverage the 2005 Hague Convention framework to reinforce jurisdictional protections in future contracts.
  • Assess risks related to service of process in foreign jurisdictions and plan for contingencies.
  • Consider the impact of US-linked commercial relationships on dispute resolution strategies.

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**Source Notes:**

Sanctions Intelligence Digest, [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/2109.html](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/2109.html)

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