[2025] EWHC 1368 (Comm)

There is “no jurisdictional requirement that an anti-enforcement injunction will only be granted in exceptional cases” (SAS Institute, [93]). It has become increasingly common for relief of this kind to be granted in anti-suit injunction cases concerning proceedings in Russia, because of the risk that the Russian court will not permit proceedings to be discontinued even if the party who has commenced those proceedings seeks such an order: see for example Deutsche Bank AG v RusChemAlliance LLC [2023] EWCA Civ 1144, [43] (Nugee LJ); Airbus Canada Ltd Partnership v Joint Stock Company Ilyushin Finance Co [2024] EWHC 790 (Comm), [24] (HHJ Pelling KC) and my judgment in Barclays Bank plc v PJSC Sovcombank [2024] EWHC 1338 (Comm), [14].

There is evidence from Mr Holiner of such a risk here. The JPM Entities clearly have assets in a number of jurisdictions against which efforts to enforce a Russian judgment might be made. In these circumstances, I am satisfied that it is appropriate to grant the anti-enforcement injunctions sought.