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ARTICLE · 05 JUNE 2026

Multi-jurisdictional Enforcement Of Arbitration Awards And Issues Of State Immunity

Withers LLP
Withers LLP
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Enforcing arbitral awards against sovereign States presents complex strategic and practical challenges, particularly when navigating sovereign immunity arguments, cross-border asset identification, and multi-jurisdictional enforcement proceedings. A recent London International Disputes Week discussion examined these issues through the lens of the landmark Zhongshan v. Nigeria case, where a Chinese investor successfully secured and enforced a USD 70 million investment arbitration award against an African Sta

United KingdomLitigation, Mediation & Arbitration
Hussein Haeri
Hussein Haeri
Christopher Birks
Christopher Birks
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Enforcing arbitral awards against sovereign States continues to present both strategic and practical challenges – particularly where assets, different jurisdictions, and Sovereign immunity arguments intersect. 

These issues were at the centre of a recent London International Disputes Week discussion co-hosted by Withers and Blackstone Chambers. The discussion drew on recent experience acting for Zhongshan Fucheng Industrial Investment Co. Ltd. ('Zhongshan') in its successful arbitration against the Federal Republic of Nigeria and subsequent enforcement efforts.

By way of background, Withers successfully represented Zhongshan in an arbitration against Nigeria for breaches of the China-Nigeria bilateral investment treaty as a result of certain actions taken by actors and entities of the Nigerian state. The arbitral tribunal, chaired by Lord Neuberger, awarded Zhongshan approximately USD 70 million in March 2021. After Nigeria failed to pay on the award, Zhongshan commenced

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