The Russian Federation sought to set aside the order granting leave to each of the three claimants to enforce a final award in its favor, claiming immunity on grounds that it had never agreed in writing to submit disputes to arbitration within the meaning of Singapore’s State Immunity Act. The Federation relied on four jurisdictional arguments previously raised in and rejected by first-instance and appellate Dutch courts in proceedings seeking to have the awards set aside at the seat. The International Commercial Court held that the doctrine of transnational issue estoppel applied to questions of state immunity, and that the Russian Federation was therefore precluded from raising this argument.