Recognition of foreign awards: illegality

In Lenkor Energy Trading DMCC v Puri [2020] EWHC 1432 (QB) Murray J considered the circumstances in which an English court could refuse to recognise or enforce the judgment of a foreign court on the ground that the contract to which it related was illegal. The case did not involve an arbitration award, but the relevant principles were regarded by Murray J as applicable in both situations. The decision makes it clear that if a foreign court has considered and rejected arguments based on illegality, there is very limited scope for the English court to invoke domestic public policy principles.

Lenkor : the facts