Seat of the arbitration: anti-suit injunctions and the seat of proceedings

Investcom Global Ltd v PLC Investments Ltd and Others [2024] EWHC 2505 (Comm); [2025] 1 Lloyd's Rep 163 was a multi-party dispute arising out of two separate contracts each containing arbitration clauses, one specifying England as the seat and the other silent. The issue was whether anti-suit injunctions could be granted. Henshaw J upheld an injunction as regards the former arbitration, but not as regards the latter.

Investcom: the facts