In an era when litigation costs continue to increase and the pathway to the courtroom is ever more fraught, when resources are better employed in creating rather then arguing, the commercially minded seek swift and financially sensible ways of dispute resolution.

Following the European Court of Justice decision in Turner v Grovit (C-159/02), there has been no doubt that under the Brussels Regulation the court of one state may not grant an anti- suit injunction to restrain proceedings brought before the court of another state, even where the party is acting in bad faith.