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ARTICLE · 05 AUGUST 2026

Trafigura PTE Ltd V Société Nationale De Raffinage

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In a significant commercial dispute, Trafigura secured a final mandatory anti-suit injunction compelling SONARA to discontinue proceedings in Cameroon that sought to suspend payment under a Letter of Credit following a quality dispute. The case centered on whether SONARA's Limbe court proceedings fell within an exception to an exclusive English jurisdiction clause for interim relief, or whether they improperly attempted to subvert the agreed 'pay now, argue later' risk allocation mechanism.

United KingdomLitigation, Mediation & Arbitration
Henry Ellis
Henry Ellis

OVERVIEW

In Trafigura PTE Ltd v Société Nationale de Raffinage [2026] EWHC 1914 (Comm), handed down by Mr Justice Michael Green on 30 July 2026, Trafigura obtained final mandatory anti-suit (ASI) relief against SONARA, obliging them to discontinue proceedings brought in the Court of First Instance of Limbe, Cameroon, to suspend payment under a Letter of Credit (LoC) following a quality dispute under a gasoline sale contract.

The sale contract contained an exclusive jurisdiction clause (EJC) in favour of the English High Court, subject to an express exception for “arrest, attachment and/or other conservatory, interlocutory or interim actions in any court…” SONARA argued the Limbe proceedings fell within the exception as they were interim in character and sought only suspensory relief, rather than determination of the quality dispute.

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