The Court of Appeal has ruled that a party to a contract containing a London arbitration clause is entitled to an anti-suit injunction on the contractual/The Angelic Grace basis against a 3rd party claiming under that contract in a foreign court pursuant to a foreign right of direct action even though there is no contract between the parties.  In so doing, the Court of Appeal in The Yusuf Cepnioglu (2016) preferred its decision in The Jay Bola (1997) to that in The Hari Bhum (No. 1) (2004). 

Chirag Karia QC of Quadrant Chambers acted for the successful claimant, The Shipowners’ P&I Club, in the Commercial Court and the Court of Appeal against Turkish charterers suing the Club in the Turkish courts under Turkey’s right of direct action against liability insurers.