9th Circuit Rules Forum Non Conveniens Does Not Apply to Foreign Arbitral Award Confirmation
The Ninth Circuit held that forum non conveniens is not a basis to oppose enforcement of foreign arbitral awards under the New York Convention.
3 reports on this incident · first at Aug 21, 2026, 3:05 a.m. ET
Earlier reports
Aug 25, 2026, 7:24 p.m. ET
9th Circuit Rules Forum Non Conveniens Inapplicable to Foreign Arbitral Award Confirmation
The U.S. Court of Appeals for the Ninth Circuit ruled that the doctrine of forum non conveniens does not apply to actions to confirm foreign arbitral awards under the New York Convention, according to the National Law Review.
The decision came in a civil appellate case involving a $1.3 billion arbitral award. The respondents are Antrix Corp. Ltd. and Devas Multimedia Private Ltd. The court's ruling continues a trend narrowing the bases for opposing enforcement of foreign arbitral awards, the National Law Review reported.
Aug 21, 2026, 3:05 a.m. ETFirst report
Ninth Circuit Rejects Forum Non Conveniens in International Arbitration Case
The Ninth Circuit Court of Appeals has issued an opinion rejecting the application of forum non conveniens in an international arbitration case, according to a report by the National Law Review. The court's decision affirms a $1.3 billion arbitral award against Antrix Corp. Ltd., the report said.
The case, which was adjudicated at the appellate level, involved a civil dispute. The National Law Review reported that the court found forum non conveniens does not apply to international arbitration proceedings. The ruling upholds the liability determination against Antrix Corp. Ltd.
The opinion is part of an ongoing legal matter, and further developments may follow.
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Revision history
- Version 125 Aug 2026, 23:53current
First published.
- Version 121 Aug 2026, 07:05current
First published.
- Version 125 Aug 2026, 23:24current
First published.
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