Arbitral Digest

Matter

Atlantic Triton v Republic of Guinea (French Court of Cassation, 18 November 1986)

  1. 26 October 1984France

    26 October 1984France

    Judgment of the Rennes Court of Appeal dated 26 October 1984

    Rennes Court of Appeal

    Decision summary
    The Rennes Court of Appeal held that the ICSID arbitration clause prevented Atlantic Triton from seeking conservatory measures in the French courts, declared the president of the commercial court incompetent to hear the application, and ordered the release of the conservatory seizure of three vessels. The Court of Cassation later quashed this judgment.

    Supporting details

    3 participants
    Atlantic Triton
    Republic of Guinea
    Soguipêche
    Rennes Court of Appeal

    2 years and 23 days later · 753 days

  2. 18 November 1986France

    18 November 1986France

    Judgment of the French Court of Cassation, First Civil Chamber dated 18 November 1986

    French Court of Cassation, First Civil Chamber

    Decision summary
    The Court of Cassation rejected the procedural challenge to the timing of the arbitration-clause objection and held that French courts may interpret the Washington Convention. It quashed the Rennes Court of Appeal judgment and held that the Convention did not itself bar a state court from ordering conservatory measures to secure a future ICSID award, absent an express or implied waiver. It also held that urgency was not required to authorize a conservatory seizure of vessels where the claim appeared founded in principle, and remanded the case to the Angers Court of Appeal.

    Supporting details

    4 authorities · 3 participants
    Atlantic Triton
    Republic of Guinea
    Soguipêche
    French Court of Cassation, First Civil Chamber

    Authorities cited

    4
    • French New Code of Civil Procedure (Article 74 of the French New Code of Civil Procedure)
      statute
    • Washington Convention of 18 March 1965 (Article 26 of the Convention on the Settlement of Investment Disputes between States and Nationals of Other States, 18 March 1965)
      treaty
    • French Decree No. 67-1245 of 18 December 1967
      statute
    • French Decree of 27 October 1967 (Article 29(2) of the French Decree of 27 October 1967)
      statute

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Atlantic Triton v Republic of Guinea (French Court of Cassation, 18 November 1986) · Matter