Court of Appeal reaches for the Stars to injunct proceedings in Pakistan to challenge LCIA award

In Star Hydro Power Limited v National Transmission and Despatch Company Limited [2025] EWCA Civ 928, the English Court of Appeal overturned the decision of Judge Dias in the High Court by granting an anti-suit injunction to restrain National Transmission and Despatch Company Limited (NTDC) from bringing pre-emptive proceedings aimed at obtaining partial recognition of an arbitration award in the Lahore High Court in Pakistan under the New York Convention 1958 (the Convention).

NTDC originally sought recognition of a single paragraph of the award and a declaration of enforceability of other parts. The High Court held that this was not an attack on the substance of the award and refused to grant an anti-suit injunction. However, the Court of Appeal found that that the substance of the proceedings in Pakistan amounted to a challenge against the Award. As such, the English Courts had exclusive jurisdiction over such challenges. The Court of Appeal therefore granted an anti-suit injunction against NTDC.

The Court of Appeal’s decision should give confidence to commercial parties who choose London as the seat for their arbitration proceedings that challenges to the arbitral award may only be heard by the English courts, which will use the powerful tools at their disposal to uphold integrity of their supervisory jurisdiction and ensure that enforcement proceedings in Convention states cannot used as a means to challenge the substance of the award.

You can read the full article from our arbitration team here.