HULLEY ENTERPRISES LIMITED & 2 Ors v THE RUSSIAN FEDERATION

[2025] SGHC(I) 19 Singapore International Commercial Court 25 July 2025 • SIC/OA 5/2025 ( HC/SUM 286/2025 ) • 90 min read
45 cases cited (13 SG, 32 foreign) Cited by 3 cases

Catchwords

Res Judicata — Issue estoppel Arbitration — Enforcement — Foreign award Arbitration — Conduct of arbitration — Estoppel International Law — Sovereign immunity — Sections 3(1) and 11(1) State Immunity Act 1979 (2020 Rev Ed)

Practice Areas

Res Judicata Arbitration International Law

Judges (3)

Andre Maniam Coram Anthony Meagher Delivered James Allsop Coram

Counsel (13)

Providence Law Asia LLC Firm WongPartnership LLP Firm Axl Rizqy Counsel Defendant Jill Ann Koh Ying (Xu Ying) Counsel Claimant Kyle Chong Kee Cheng Counsel Defendant Lau Hui Ming Kenny Counsel Defendant Lin Weiqi Wendy Counsel Claimant Sean Koh Counsel Claimant Soh Kheng Yau Andre Counsel Claimant Vergis S Abraham Counsel Defendant Wee Jong Xuan Counsel Claimant Yap Zhan Ming Counsel Claimant Zhan Xiangyun Counsel Claimant

Parties (4)

Hulley Enterprises Ltd Claimant The Russian Federation Defendant Veteran Petroleum Ltd Claimant Yukos Universal Ltd Claimant

Case Significance

[2025] SGHC(I) 19 is a Singapore International Commercial Court decision dated 25 July 2025 concerning Arbitration, International Law, and Res Judicata, specifically addressing issue estoppel, enforcement, and conduct of arbitration. The judgment was delivered by Anthony Meagher, with Andre Maniam and James Allsop on the coram. The case was brought by Hulley Enterprises Ltd and others (claimant) against The Russian Federation (defendant). Legal representation was provided by WongPartnership LLP and Providence Law Asia LLC. The judgment cites 45 cases (13 Singapore, 32 foreign) and references 4 statutory provisions, including the Arbitration Act, the International Arbitration Act, and the State Immunity Act. This decision has been cited by 3 subsequent judgments in the dataset.

Summary

Three former Yukos shareholders sought to enforce arbitral awards totalling approximately US$50 billion against the Russian Federation in Singapore. The Russian Federation applied to set aside the enforcement order on sovereign immunity grounds. The SICC dismissed the sovereign immunity challenge, holding that the Russian Federation was estopped by the Dutch courts' final decision that it had agreed in writing to submit to arbitration under the Energy Charter Treaty.

What was decided in [2025] SGHC(I) 19?

[2025] SGHC(I) 19 (HULLEY ENTERPRISES LIMITED & 2 Ors v THE RUSSIAN FEDERATION) is a Singapore International Commercial Court decision from 25 July 2025 addressing Arbitration, International Law, and Res Judicata, specifically issue estoppel, enforcement, and conduct of arbitration. The judgment was delivered by Anthony Meagher.

Who were the parties in HULLEY ENTERPRISES LIMITED & 2 Ors v THE RUSSIAN FEDERATION?

The claimant in [2025] SGHC(I) 19 was Hulley Enterprises Ltd, Veteran Petroleum Ltd, and the defendant was The Russian Federation. Legal representation included Providence Law Asia LLC and WongPartnership LLP. The case was decided on 25 July 2025 in the Singapore International Commercial Court.

Which judge decided [2025] SGHC(I) 19?

[2025] SGHC(I) 19 was delivered by Anthony Meagher in the Singapore International Commercial Court on 25 July 2025. Andre Maniam and James Allsop also sat on the coram. The case concerned Arbitration, International Law, and Res Judicata.

What cases and statutes does [2025] SGHC(I) 19 cite?

[2025] SGHC(I) 19 cites 45 prior decisions, including 32 from foreign jurisdictions. It references Arbitration Act, International Arbitration Act, State Immunity Act. The decision has itself been cited by 3 subsequent judgments.

Statutes Cited

Arbitration Act (Cap 10)
s 66
International Arbitration Act (Cap 143A)
s 29
State Immunity Act
s 1 s 2(7) s 3(1) s 9
The claim was the subject of an adjudication application under the Building and Construction Industry Security of Payment Act (Cap 30B)

Cases Cited (45)

SLR (13)
[2006] 2 SLR(R) 830 [2010] 1 SLR 658 [2010] 3 SLR 489 [2014] 1 SLR 372 [2015] 2 SLR 352 [2015] 2 SLR 972 [2015] 5 SLR 1104 [2016] 4 SLR 1336 [2016] 5 SLR 536 [2021] 1 SLR 1102 [2022] 3 SLR 145 [2024] 1 SLR 56 [2024] 3 SLR 1
UK (32)
[1894] 1 QB 149 [1938] AC 485 [1939] AC 160 [1947] AC 209 [1967] 1 AC 853 [1972] AC 1027 [1975] AC 774 [1975] Ch 397 [1976] 1 WLR 248 [1977] AC 373 [1977] QB 529 [1983] 1 AC 244 [1984] AC 580 [1989] Ch 72 [1991] 2 AC 33 [2001] QB 955 [2003] 1 WLR 1041 [2007] 1 AC 270 [2007] QB 886 [2011] AC 763 [2011] QB 8 [2012] EWCA Civ 41 [2017] AC 964 [2019] AC 777 [2021] 1 WLR 1123 [2022] 1 WLR 3434 [2022] AC 318 [2022] EWHC 2690 [2023] 1 WLR 1162 [2023] EWCA Civ 867 [2024] KB 208 [2025] EWCA Civ 108

Cited By (3)

[2026] SGHC 43
NEXTERA ENERGY GLOBAL HOLDINGS B.V. & Anor v KINGDOM OF SPAIN
[2025] SGHC(I) 27
HULLEY ENTERPRISES LIMITED & 2 Ors v THE RUSSIAN FEDERATION
[2025] SGHC 182
AMIR MOHAMED NURUSSALAAM BIN MOHAMED LOFTI & 10 Ors v PERSEKUTUAN KEBAJIKAN ISLAM TELUK KURAU SINGAPURA & 18 Ors

Judgment

Read the full judgment on the official Singapore Courts portal.

Read on eLitigation

Source: eLitigation ([2025] SGHC(I) 19)