Introduction

The English Courts have for many years exercised jurisdiction to restrain foreign court proceedings brought by a party in breach of an arbitration agreement where the seat of the arbitration is England.[1] This supervisory power is generally regarded by commercial parties as an important advantage of choosing England as the seat of the arbitration. In contrast, the courts of other EU Member States have shown themselves generally unwilling to grant anti­suit injunctions in support of arbitration. The granting of anti­suit injunctions by the English Courts, as ...