Voluntary Submission To Jurisdiction: Avoiding Costly Mistakes

Following on from the leading British Virgin Islands ("BVI") case of Star Reefers Pool Inc v JFC Group Co. Ltd¹ ("Star Reefers"), further helpful guidance has been provided as to what can amount to a voluntary submission to jurisdiction in the recently handed down judgment in Concept Oil Services Limited v Alexander Kontsevoy & Ors² ("Concept Oil"). 

Background

The matter was an application without notice under the BVI Reciprocal Enforcement of Judgments Act 1992 to register an English judgment in the BVI.  The only live issue under the relevant test was whether the respondents, as defendants in the English proceedings, had voluntarily or otherwise submitted to the jurisdiction of the English Court.