Based on the arbitration clause in bonds between the parties, UniCredit had obtained a final anti-suit injunction (UNITED KINGDOM 128) ordering RusChem not to pursue court proceedings in Russia. A Russian court had subsequently prohibited UniCredit from pursuing arbitration or court proceedings, or from enforcing judgments, in respect of the bonds anywhere except the Russian courts, on pain of a substantial penalty. UniCredit had then applied to revoke or vary the earlier anti-suit inunction. The Court of Appeal granted the application, though noting that UniCredit might have been coerced into making it.