Anti-enforcement Injunction, Anti-suit injunction, Comity, Conflict of Laws, Enforcement, English courts, Situs of a Debt
SAS Institute Inc v World Programming Limited: Anti-enforcement Injunctions and Competing Judgments on Liability and Enforcement
In the recent decision in SAS Institute Inc v World Programming Limited [2020] EWCA Civ 599 (“SAS”), the English Court of Appeal addressed issues including the situs of a debt, the proper approach to anti-enforcement injunctions, and how considerations of comity arise in the enforcement of foreign decisions. Facts In 2009, SAS, a North…