The judgment had been obtained by Russian company, Eurochem North-West-2 (“Eurochem”) against Italian engineering company, Tecnimont S.p.A. (“Tecnimont”), and Eurochem sought to enforce it against Tecnimont’s assets in India. The Court refused to recognise the Moscow Commercial Court’s judgment due to:(i) its doubts regarding the Moscow Court’s competence, given the parties’ arbitration agreement and Eurochem’s participation in the arbitration proceedings; and(ii) its concerns regarding procedural fairness. In essence, the Lugovoy Law grants Russian courts exclusive jurisdiction over disputes involving sanctioned Russian parties, even if parties have agreed on a dispute resolution mechanism (such as arbitration), if the agreed foreign forum is deemed “unavailable” or “unenforceable” because sanctions impede the sanctioned party’s access to justice. Eurochem subsequently sought to enforce the judgment in India, filing proceedings before the Bombay High Court under Section 13 of the Code of Civil Procedure 1908 (“CPC”). Under Section 14 of the CPC, Indian courts ordinarily presume that a foreign court was competent where a certified copy of a foreign judgment is produced.