Interim measures: challenge to tribunal’s decision test

In JKD and Another v IKC [2026] EWHC 2031 (Comm); [2026] 2 Lloyd’s Rep 219 an ICC Tribunal refused to grant interim measures to the applicant, the effect of which would have been to prevent the respondent from calling on performance bonds issued by a third-party bank. The question in the present case was whether the tribunal’s decision was capable of challenge under the Arbitration Act 1996. Dias J concluded that no challenge was possible.