Enforcement, Enforcement of arbitration agreement, French Supreme Court, Jurisdiction of the arbitral tribunal, Paris Court of Appeal, Pathological arbitration agreement
Towards the End of the ‘Sultan de Sulu’ Case in France: The Hidden Influence of the New York Convention on French Law on Enforcement of Arbitral Awards?
The famous saga Sultan de Sulu is coming to an end in France with the French Cour de cassation (Cass. Civ. 1re 6 November 2024, hereinafter the “Ruling”) upholding the Paris Court of Appeal’s decision to refuse the enforcement of the preliminary award whereby the sole arbitrator affirmed his jurisdiction and determined the seat of…