Paris Court of Appeal, 25 May 2021 – Libya v. Cengiz (RG No. 18/27648) and Gabon v. Webcor (RG No. 18/18708)

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Signature Litigation

More on annulment of arbitral awards on corruption grounds.

On 25 May 2021, the Paris Court of Appeal decided two different cases in which allegations of corruption were invoked to set aside international arbitral awards providing yet more examples of decisions rendered on such grounds.The decision concerning the Republic of Gabon annulled the award on the ground that a luxurious honeymoon trip as wedding gift was a red flag of corruption. The Court describes the trip in detail: business class tickets to Cape Town, Johannesburg, Durban and a Suite at the Twelve Apostles Hotel including a “heavenly honeymoon package“… evidenced by a letter confirming to a Gabonese official the fulfilment of all his requests concerning his itinerary.In the decision concerning the Republic of Libya, an atmosphere of corruption, links with the former head of State and distantly related corruption indictments were not considered sufficient evidence of corruption. The Court notes that allegations of corruption were not specific enough as the corrupt individuals were not identified nor was the allegedly corrupt State entity.

These cases show that corruption is not a password to annulment in France.

Libya v Cengiz (RG n° 18/27648)

Gabon v Webcor (RG No. 18/18708)

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