African Fertilizers and Chemicals NIG Ltd (Nigeria) v BD Shipsnavo GmbH & Co Reederei KG (The "Christian D") - QBD (Comm Ct) (Beatson J) - 29 September 2011

Arbitration - Award - Enforcement - Whether court has jurisdiction to enforce a purely declaratory award - Whether order constituted a "judgment" - Arbitration Act 1996 section 66, Council Regulation (EC) No 44/2001 Article 34(3)

Disputes arose between shipowners and cargo owners under a bill of lading issued in respect of cargo carried onboard the vessel Christian D following the grounding of the vessel in Romanian waters and the subsequent declaration of General Average.