Arbitral Digest

Matter

Commissions Import Export (Commisimpex) v Republic of the Congo (French Court of Cassation, No. 13-17.751)

  1. 3 December 2000Arbitration

    14 years, 5 months and 10 days later · 5274 days

  2. 13 May 2015France

    13 May 2015France

    Judgment of the French Court of Cassation, First Civil Chamber, dated 13 May 2015

    French Court of Cassation, First Civil Chamber

    Citation
    French Court of Cassation, First Civil Chamber, 13 May 2015, No. 13-17.751
    Decision summary
    The court quashed the Versailles Court of Appeal judgment that had required a special waiver of State execution immunity for attachment of accounts held for the Congolese diplomatic mission and remitted the case to the Paris Court of Appeal. It held that customary international law required an express waiver, not an additional special waiver.

    Supporting details

    4 authorities · 3 participants
    Commissions Import Export (Commisimpex)
    Representative
    SCP Ortscheidt (For: Commissions Import Export (Commisimpex))
    Republic of the Congo
    French Court of Cassation, First Civil Chamber

    Authorities cited

    4
    • Customary international law on State immunity from enforcement
      case-law
    • French Code of Civil Enforcement Procedures
      statute
    • Statute of the International Court of Justice (Article 38(1)(b))
      statute
    • French Code of Civil Procedure
      statute

    2 years, 7 months and 28 days later · 973 days

  3. 10 January 2018France

    10 January 2018France

    Judgment of the French Court of Cassation, First Civil Chamber, dated 10 January 2018

    French Court of Cassation, First Civil Chamber

    Case no.
    F 16-22.494
    Citation
    French Court of Cassation, First Civil Chamber, 10 January 2018, No. 16-22.494
    Decision summary
    The court annulled without remand the Paris Court of Appeal judgment validating Commisimpex's attachments, confirmed the Nanterre enforcement judgment, and rejected the parties' claims for costs. It applied the statutory conditions governing State execution immunity and the diplomatic protection of the attached accounts.

    Supporting details

    6 authorities · 4 participants
    Republic of the Congo
    Representative
    SCP Rousseau and Tapie (For: Republic of the Congo)
    Commissions Import Export (Commisimpex)
    Representative
    SCP Ortscheidt (For: Commissions Import Export (Commisimpex))
    French Court of Cassation, First Civil Chamber

    Authorities cited

    6
    • Vienna Convention on Diplomatic Relations of 18 April 1961
      statute
    • Customary international law on State immunity from enforcement
      case-law
    • French Code of Civil Enforcement Procedures
      statute
    • Law No. 2016-1691 of 9 December 2016
      statute
    • French Code of Judicial Organisation
      statute
    • French Code of Civil Procedure
      statute

    1 year, 8 months and 22 days later · 630 days

  4. 2 October 2019France

    2 October 2019France

    Constitutional Question Judgment of the French Court of Cassation, First Civil Chamber, dated 2 October 2019

    French Court of Cassation, First Civil Chamber

    Case no.
    Q 19-10.669
    Citation
    French Court of Cassation, First Civil Chamber, 2 October 2019, No. Q 19-10.669
    Decision summary
    The court held that there was no need to refer to the Constitutional Council the priority constitutional question concerning the statutory rules governing waiver of State immunity from enforcement in the Commisimpex proceedings.

    Supporting details

    4 authorities · 8 participants
    Commissions Import Export (Commisimpex)
    Representative
    SCP Ortscheidt (For: Commissions Import Export (Commisimpex))
    Republic of the Congo
    Representative
    SCP Gouz-Fitoussi (For: Republic of the Congo)
    Prosecutor General at the Paris Court of Appeal
    French Court of Cassation, First Civil Chamber
    Advocate General
    Caron-Déglise
    Judge
    Batut

    Authorities cited

    4
    • French Code of Civil Enforcement Procedures
      statute
    • Law No. 2016-1691 of 9 December 2016 on transparency, the fight against corruption and the modernisation of economic life (Law No. 2016-1691 of 9 December 2016)
      statute
    • French Court of Cassation, First Civil Chamber, 10 January 2018, No. 16-22.494 (16-22.494)
      case-law
    • French Court of Cassation, First Civil Chamber, 24 January 2018, No. 16-16.511 (16-16.511)
      case-law

    3 years, 6 months and 11 days later · 1289 days

  5. 13 April 2023France

    13 April 2023France

    Judgment of the French Court of Cassation, First Civil Chamber, dated 13 April 2023

    French Court of Cassation, First Civil Chamber

    Case no.
    T 18-24.859
    Citation
    French Court of Cassation, First Civil Chamber, 13 April 2023, No. T 18-24.859
    Decision summary
    The court rejected the Republic of the Congo's appeal concerning Commisimpex's attachment of tax and other receivables owed to the Republic by EDF Africa Services. It upheld the enforcement decision and rejected the parties' costs applications.

    Supporting details

    3 authorities · 6 participants
    Republic of the Congo
    Representative
    SCP Gouz-Fitoussi (For: Republic of the Congo)
    Commissions Import Export (Commisimpex)
    Representative
    SARL Ortscheidt (For: Commissions Import Export (Commisimpex))
    EDF Africa Services
    French Court of Cassation, First Civil Chamber
    Advocate General
    Salomon

    Authorities cited

    3
    • French Code of Civil Procedure
      statute
    • French Civil Code (Article 2284)
      statute
    • Customary international law on State immunity from enforcement
      case-law

    1 year, 5 months and 6 days later · 525 days

  6. 19 September 2024France

    19 September 2024France

    Judgment of the Paris Court of Appeal, Division 1, Chamber 10, dated 19 September 2024

    Paris Court of Appeal, Division 1, Chamber 10

    Case no.
    RG 23/09300
    Decision summary
    The court declared inadmissible the Presidency of the Republic of the Congo's third-party challenge to the Paris Court of Appeal judgment of 3 June 2021. It held that the Presidency was not distinct from the Republic of the Congo for this purpose and ordered the Republic to pay Commisimpex EUR 15,000 in costs.

    Supporting details

    2 authorities · 10 participants
    Presidency of the Republic of the Congo
    Representative
    Matthieu Boccon Gibod (For: Presidency of the Republic of the Congo)
    Representative
    Simon Ndiaye (For: Presidency of the Republic of the Congo)
    Republic of the Congo
    Commissions Import Export (Commisimpex)
    Representative
    Jacques-Alexandre Genet (For: Commissions Import Export (Commisimpex))
    Paris Court of Appeal, Division 1, Chamber 10
    Other
    Court Reporter
    Grégoire Grospellier

    Authorities cited

    2
    • French Code of Civil Procedure
      statute
    • Decree of the Presidency of the Republic of the Congo dated 11 August 2020 (Decree dated 11 August 2020)
      statute

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Commissions Import Export (Commisimpex) v Republic of the Congo (French Court of Cassation, No. 13-17.751) · Matter