Arbitration in Africa

Arbitration in Egypt

Challenging jurisdiction in Egypt

This Practice Note sets out the legal grounds for challenging the jurisdiction of Egyptian courts. For further information, see Practice Note: Challenging jurisdiction in Egypt.

Enforcement of international arbitral awards in Egypt

This Practice Note sets out the legal regime governing enforcement of international arbitral awards in Egypt. For further information, see Practice Note: Enforcement of international arbitral awards in Egypt.

Interim measures in support of arbitration in Egypt

This Practice Note sets out the types of interim measures in support of arbitration that are available in Egypt and the conditions that must be satisfied to grant them. For further information, see Practice Note: Interim measures in support of arbitration in Egypt.

State immunity and arbitration in Egypt

This Practice Note considers the role of state immunity in relation to arbitration proceedings in Egypt. For further information, see Practice Note: State immunity and arbitration in Egypt.

Arbitration in Mauritius

Arbitration in Mauritius—an introduction

This Practice Note provides an introduction to the domestic and international arbitration legislation as it applies in Mauritius (under Mauritian

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Latest Arbitration News

French courts re-affirmed how the irreconcilability between an arbitral award and a foreign judgment may amount to a breach of international public policy (SNEL v Congo and FG Hemisphere)

Arbitration analysis: On 16 September 2025, the Paris Court of Appeal (the Court) dismissed Congolese company Société Nationale d’Électricité (SNEL)’s application to set aside an ICC award rendered against it and the Democratic Republic of Congo, confirming France’s pro-enforcement stance. The Court held that as a matter of principle, the irreconcilability between an arbitral award and a non-EU foreign judgment may amount to a breach of international public policy in circumstances where the foreign judgment has first obtained exequatur in France and the irreconcilable decisions result in mutually exclusive consequences. In the present case, because the Congolese judgment relied upon by SNEL had been denied exequatur for lack of proper notice to the opposing party, no irreconciliability could arise. The Court reaffirmed that the mere disregard of a foreign judgment’s res judicata effect by an arbitral award is not, in and of itself, contrary to international public policy. The Court further clarified that the exequatur judge exercises only limited review, verifying the existence of the arbitral award and the absence of any manifest breach of international public policy, dismissing SNEL’s other arguments based on capacity to arbitrate, arbitrability, and foreign procurement rules, which did not amount to a breach of French international public policy. Written by Julie Spinelli, partner at Le 16 Law, and Carl Szymura, associate at Le 16 Law.

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