PAKISTAN 2026-1

High Court, Islamabad, 24 October 2024

(Zaver Petroleum Corporation (Pvt.) Limited v. Saif Energy Limited)

24 - 10 - 2024

PAKISTAN 2026-1

Yearbook Yearbook Commercial Arbitration, S. W. Schill (ed.), Vol. LI (2026)
Jurisdiction Pakistan
Summary

The High Court granted enforcement of three LCIA awards, explaining inter alia that Pakistani parties may opt for a foreign arbitration seat and the application of a foreign law in respect of a contract concluded and to be performed in Pakistan. The Court rejected Saif’s argument that Zaver could not commence arbitration before the annulment of the status quo order Saif had obtained in the context of court proceedings it had commenced in Pakistan seeking cancellation of the agreement containing the arbitration clause. The status quo order, the Court found, went against the mandate of Art. II of the New York Convention, which requires courts to recognize arbitration agreements and to refer disputes covered by an arbitration agreement to arbitration.

Related topics
218

The court discusses whether referral of the resolution of disputes to arbitration is mandatory under the Convention and whether mandatory referral is an internationally uniform rule which supersedes municipal law.

Referral is mandatory
301

The court discusses the principle that the procedure for the enforcement of awards under the Convention is governed by the lex fori, as well as procedural issues (such as the competent enforcement court) not falling under the specific cases of ¶¶ 302-307.

Procedure for enforcement in general
303

The court discusses the conditions under which a party may be estopped from raising a ground for refusal of enforcement under the Convention or has waived the right to raise it.

Estoppel/waiver
404

The court discusses issues relating to the manner of authentication and certification of the award and/or arbitration agreement.

Authentication and certification
500

The court discusses the overall scheme and/or pro-enforcement bias of the Convention.

Grounds for refusal of enforcement in general
513 Ground d: Irregularity in the composition of the arbitral tribunal or arbitral procedure
524

Public policy: The court discusses the effect of other alleged violations of public policy on the recognition and enforcement of an arbitral award, such as contradictory reasons, manifest disregard of the law (US), etc.

Other cases
PAKISTAN 2026-1