EEEL obtained an ICC award in Paris against Vijay Construction. It then sought to have the award enforced in Seychelles – unsuccessfully, as in 2017, the Seychelles Court of Appeal denied the application on the ground that Seychelles was not a party to the New York Convention (Seychelles no. 1). EEEL also obtained two enforcement orders on the award in the United Kingdom, and sought to enforce them in Seychelles. On 30 June 2020 INSERT LINK, the Supreme Court of Seychelles granted enforcement of the UK enforcement orders. By the present decision, the Court of Appeal denied the appeal filed by Vijay Construction against this decision. The Court examined, inter alia, the argument that it was not just and convenient for the Supreme Court to enforce the UK orders because enforcing them was tantamount to trying to enter through the back door after the Court of Appeal had closed the front door in 2017 when it held that the award was not enforceable in Seychelles. The Court of Appeal dismissed this argument, holding that there could be no res judicata, because, while the parties and the subject matter were the same, the cause of action was different: the enforcement of an award in 2017, and the enforcement of orders of a state court now.