The Commercial Court of Moscow has overturned its earlier decision recognising and enforcing a SIAC award in favour of the Russian company Power Machines against Petrovietnam. The court will reconsider enforcement after the Singapore court partially set aside the award, an unexpected development given the claimant’s Russian domicile and the Russian court’s prior refusal to stay the enforcement proceedings.
The Commercial Court of Moscow has reversed its previous decision recognising and enforcing a SIAC award in Russia in favour of Power Machines, a Russian company, against Vietnamese company Petrovietnam.
The award was the subject of set-aside proceedings before the Singapore High Court. While those proceedings were pending, the Singapore court suspended the award. Power Machines nevertheless applied to the Moscow court for recognition and enforcement in Russia. The Moscow court granted the application, declining to suspend the Russian enforcement proceedings pending determination of Petrovietnam’s application to set aside the award in Singapore.
During the setting aside proceedings, the General Division of the Singapore High Court found grounds to set aside parts of the SIAC award but remitted the affected issues to the tribunal. On appeal, the Singapore Court of Appeal set aside paragraph 548 of the award and all consequential parts in <span class="news-text_italic-underline">Vietnam Oil and Gas Group v Joint Stock Company (Power Machines – ZTL, LMZ, Electrosila Energomachexport) and another appeal [2025] SGCA 50</span>. Petrovietnam then applied to the Moscow court for reconsideration of its earlier enforcement decision under Article V(1) of the <span class="news-text_italic-underline">New York Convention</span>.
Taking account of the Singapore court’s decision, the Commercial Court of Moscow set aside its own earlier recognition and enforcement ruling. It returned the question of recognition and enforcement of the award for fresh consideration.
The court will determine whether the award’s partial annulment at the seat requires it to refuse enforcement under Article V(1)(e) of the <span class="news-text_italic-underline">New York Convention</span>.
The decision is important for several reasons. First, the Moscow court had previously declined to suspend enforcement proceedings while the Singapore set-aside application was pending. Its subsequent reconsideration of the enforcement ruling therefore gives material weight to the latter decision of the courts at the seat.
Second, the SIAC award was issued in favour of a large Russian company. It is consequently unusual for a Russian court to revisit enforcement in circumstances that could result in refusal of enforcement.
Third, Singapore is treated by Russia as an ‘unfriendly’ state. The Moscow court’s willingness to regard a Singapore court judgment as a significant circumstance is therefore particularly noteworthy.
There is no existing settled approach in Russian case law on whether partial annulment of an award at the seat obliges a Russian court to refuse enforcement under Article V(1)(e) of the <span class="news-text_italic-underline">New York Convention</span>. The Moscow court’s decision at the next hearing will therefore be of considerable interest to parties involved in the enforcement of foreign arbitral awards in Russia.
<span class="news-text_medium">Case:</span> <span class="news-text_italic-underline">Case No. A40-20468/24-19-154</span>, Commercial Court of Moscow, 8 July 2026.
