Foreign Sovereign Immunity in Exequatur Proceedings

Notes on the District Court of The Hague’s Decision of 5 June 2025

Authors

DOI:

https://doi.org/10.20318/cdt.2026.10299

Keywords:

2019 Hague Judgments Convention, sovereign immunity, territorial tort exception, Ukraine, Russia

Abstract

On 5 June 2025, the District Court of The Hague rejected the request for exequatur of a Ukrainian ruling holding energy giant Gazprom jointly and severally liable for damages caused by the Russian Federation in Ukraine. Despite the entry into force of the 2019 Hague Judgments Convention between Ukraine and the Netherlands, the Dutch judge declared itself incompetent on foreign sovereign immunity grounds. This decision underscores the close interplay between private and public international law, raising important questions about the future circulation of judgments during periods of high legal and geopolitical uncertainty.

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Published

2026-03-26

Issue

Section

Varia

How to Cite

Foreign Sovereign Immunity in Exequatur Proceedings: Notes on the District Court of The Hague’s Decision of 5 June 2025. (2026). CUADERNOS DE DERECHO TRANSNACIONAL, 18(1), 752-764. https://doi.org/10.20318/cdt.2026.10299