What happened
The dispute concerns an EPC project to build an ammonia complex in Kingisepp. The contracts, concluded in 2020, provided for ICC arbitration seated in London. In 2022, Tecnimont group contractors commenced ICC arbitration challenging the termination of the contracts by EuroChem North-West 2 LLC. In parallel, EuroChem North-West 2 pursued proceedings in Russia under Article 248.1 of the Russian Arbitrazh Procedure Code: on November 27, 2025, the Moscow Arbitrazh Court ordered Tecnimont S.p.A. and MT Russia LLC to pay over ₽171B, and on December 10, 2025, the Arbitrazh Court of St. Petersburg and the Leningrad Region barred Tecnimont from continuing the ICC arbitration. The English court responded in kind: on November 21, 2025, Justice Butcher issued a penal notice against EuroChem North-West 2, and in June 2026 Justice Henshaw, on the application of the parent company Maire S.p.A., granted an anti-suit injunction against the Russian proceedings on the guarantees, finding those proceedings unduly harsh and oppressive. In India, on June 8, 2026, the Bombay High Court, having initially granted interim measures against Tecnimont, ultimately refused EuroChem North-West 2’s application to attach Tecnimont’s assets. However, that order was appealed, and Tecnimont’s undertaking not to dispose of its assets was reinstated and extended, which in effect reinstates the court-ordered attachment.
Why it is notable
A multi-level conflict of competing injunctions, in which the Russian courts, relying on Article 248.1 of the Russian Arbitrazh Procedure Code, awarded over ₽171B and barred the ICC arbitration, while the English courts responded in kind by restraining the Russian proceedings (including those on the Maire guarantees) and issuing a penal notice. The dispute is also one of the first cases on the recognition outside Russia of a Russian court judgment issued under Article 248.1 of the Russian Arbitrazh Procedure Code.