Larina Mokaled

Paris Court of Appeal, Sector 5 chamber 16 (Pôle 5 Chambre 16), 9 December 2025 – n° 25/01855 In a significant decision for international arbitration in France, the Paris Court of Appeal confirmed the exequatur of an ICC award in favour of Enka Renewables LLC while simultaneously ordering a stay of its enforcement under Article 1526(2) of the French Code of Civil Procedure.

Paris Court of Appeal, Sector 5 chamber 16 (Pôle 5 Chambre 16), 9 December 2025 – n° 25/01855 In a significant decision for international arbitration in France, the Paris Court of Appeal confirmed the exequatur of an ICC award in favour of Enka Renewables LLC while simultaneously ordering a stay of its enforcement under Article 1526(2) of the French Code of Civil Procedure.

Commented decision: Paris Court of Appeal (Department 5 – Chamber 16), 9 December 2025, n°22/04007[1] On 9 December 2025, the Paris Court of Appeal annulled a USD 14.92 billion arbitral award rendered against Malaysia in favor of the heirs of the Sultan of Sulu. The Court held that the arbitration agreement contained in an 1878 agreement was inapplicable because a decisive and indivisible element of the parties’ consent—the reference to the British Consul General in Borneo—had disappeared.