Englische anti-suit injunctions zur Durchsetzung von Schiedsvereinbarungen

Ingrid Naumann provides a thorough and detailed analysis of whether anti-suit injunctions in support of arbitration agreements are compatible with the principle of international comity, the New York Convention and in particular with European civil procedural law. A comparative analysis demonstrates the reasons why civil law jurisdictions like Germany perceive anti-suit injunctions as an unjustified interference with their proceedings. The study encompasses an extensive discussion of the jurisprudence of the ECJ and the English courts.