SPEC 1 LTD V THE EXPORT-IMPORT BANK OF CHINA

[2026] EWHC 1162 (Comm), King's Bench Division, Commercial Court, Mr Justice Bright, 15 May 2026

Conflict of laws – Jurisdiction – Asymmetric jurisdiction clause – Stay of proceedings – Anti-suit injunction

In 2015 the Lender entered into ship finance arrangements with the Original Borrowers. In April 2024 the Original Borrowers were replaced by Borrowers in a series of interlocking agreements including a Novated, Amended and Restated Secured Loan Agreement ("NAR Loan Agreement") between the Lender and all the Borrowers (contracting jointly and severally).