Arbitration analysis: This case involved a dispute between Garuda Indonesia’s French subsidiary, Garuda Indonesia Holiday France (Garuda France), which faced financial difficulties due to the coronavirus (COVID-19) pandemic, and one of its aircraft lessors, Greylag Goose Leasing 1446 Designated Activity Company (Greylag). Greylag sought US$43,635,485, for unpaid rent and most of the maintenance reserves owed. While the dispute was subject to arbitration proceedings conducted under the rules of the Singapore International Arbitration Centre (SIAC), Greylag sought to initiate parallel recovery proceedings against Garuda France. This application was however dismissed by the Paris Commercial Court on 25 November 2022. The Paris Court of Appeal rejected Greylag’s appeal from this decision on 14 December 2023. Considering the requirement, under French law, that a claim must be certain for a creditor to commence recovery proceedings, the judge inferred from the ongoing arbitration proceedings that Greylag’s claim remained uncertain. Written by Sara Nadeau-Seguin, partner at Teynier Pic.