Arbitration Yearbook Russia

By: Vladimir Khvalei1 and Irina Varyushina2

A. Legislation, Trends and Tendencies

A.1 Legislation

International arbitration in Russia is governed by the 1993 Law on International Arbitration (the “ICA Law”),3 which, when it was adopted, was almost an identical copy of the UNCITRAL Model Law. However, in 2015, as part of an arbitration reform conducted in Russia, a new law on domestic arbitration (“New Law on Domestic Arbitration”)4 was introduced. Significant changes were also made to the ICA Law, resulting in the revised ICA Law (“New ICA Law”).5

First, the New ICA Law has a seriously reduced scope of application when compared to the scope of application of the ICA Law. Under the ICA Law, one can refer to international arbitration not only international disputes (disputes between Russian and foreign entities), but also disputes solely involving Russian companies with foreign investments, disputes between shareholders of Russian companies with foreign investments, as well as disputes between Russian companies with foreign investments and other Russian companies and individuals.6 The latter have been excluded in the new law, and now, disputes between Russian companies with foreign investments and other Russian entities are subject to the Law on Domestic Arbitration.7

Second, some of the provisions of the New ICA Law were prompted by the changes made in 2006 to the UNCITRAL Model Law (which mainly concerned the form of the arbitration agreement and interim measures in arbitration). Although the New ICA Law still does not accept arbitration agreements concluded in an oral form, the written form requirement is deemed fulfilled if the information is recorded in a manner that enables it to be subsequently used. Also, the New ICA Law has introduced a concept of a written arbitration agreement in electronic form. However, the New ICA Law has not implemented the 2006 UNCITRAL Model Law provisions related to interim measures. While the New ICA Law recognizes the authority of arbitral tribunals (and emergency arbitrators appointed by institutions) to issue interim measures binding on the parties, these decisions are not directly enforceable by state courts.8

Third, the New ICA Law and New Law on Domestic Arbitration introduce the concept of “direct agreement.” Terms which under the new laws9 are to be agreed only by “direct agreement” must be included in the arbitration clause itself rather than incorporated in the arbitration rules to which the arbitration clause refers. For example, only by direct agreement can parties to institutional arbitration exclude the right to apply to the state court to set aside a decision on jurisdiction or a final arbitral award.10

Fourth, the arbitration reform is gradually making corporate disputes arbitrable subject to certain conditions. For a long time, Russian courts have considered corporate disputes as nonarbitrable, with a very broad and vague definition of “corporate disputes.” Although the new laws do not define “corporate disputes,” they do provide a list of nonarbitrable corporate disputes. These are disputes:11 (a) on convening a general meeting of a legal entity’s participants; (b) related to a notary’s actions on certifying transactions with LLC shares; (c) in respect of companies of strategic importance for the Russian state (with certain exceptions); (d) on the acquisition and buyout of shares in public joint stock companies; (e) related to the exclusion of participants in a legal entity; and (f) on challenging decisions of state agencies on issues related to the establishment, reorganization and liquidation of a legal entity, as well as those in connection with emission of securities. All other corporate disputes are arbitrable, subject to certain conditions.12 The New ICA Law also provides that an arbitration agreement may be included in the charter of a company subject to the unanimous approval of the general participants’ meeting, with the exception of public joint stock companies and joint stock companies with more than 1,000 shareholders.13

Fifth, there are significant changes aimed at the regulation of domestic arbitration institutions. Some of these have an impact on international arbitration administered by foreign arbitration institutions in Russia. Thus, arbitral institutions in Russia can be established only by noncommercial organizations. In order to establish a permanent arbitration institution, such organizations must obtain a special authorization.14 The authorization is issued by the Russian government on the basis of a recommendation of a special body (Center For Development of Arbitration, the “Center”).15 In the course of preparing the recommendation, the Center is to check the compliance of the applicant with certain stipulated requirements16 or, for foreign arbitral institutions, which are exempt from the above requirements, to check whether they have “a reputation recognized worldwide,” which is the basis for granting the authorization to foreign arbitral institutions.17 If a foreign arbitral institution fails to get the authorization, awards made under the rules of this institution with a place of arbitration in Russia will be deemed to have been rendered in ad hoc proceedings.18

Foreign arbitral institutions that fail to obtain authorization to administer disputes and thus will not be considered as “permanent arbitral institutions”19 will not be able to administer corporate disputes in Russia. In addition, they will not have the benefit of a number of legal provisions that apply only to permanent arbitral institutions. Notably, the parties will not be able to exclude the possibility of applying to a state court for (i) a challenge to an arbitrator;20 (ii) termination of an arbitrator’s authority in the event of his or her inability to perform his or her functions;21 (iii) a challenge to an award or decision on jurisdiction;22 or (iv) the setting aside of the final award.23

Sixth, the New ICA Law introduced rules for the interpretation of the arbitration agreement. In interpreting an arbitration agreement, all doubts must be interpreted in favor of the agreement’s validity and enforceability. The New ICA Law also provides that: (i) an arbitration agreement survives an assignment of the contract; and (ii) an arbitration clause covers all disputes related to the conclusion of the contract, its performance, termination, etc., unless otherwise provided by the arbitration agreement itself.

Seventh, the function of the default appointing authority is reassigned from the President of the Russian Chamber of Commerce and Industry to state courts.24

Eighth, the New ICA Law provides a special procedure for objecting to the recognition in Russia of foreign arbitral awards that, by their nature, do not require enforcement in Russia.25

Ninth, the requirements for arbitrators’ qualifications introduced by the New Law on Domestic Arbitration are also applicable to international arbitrations seated in Russia. One of them is that sole or presiding arbitrators must have a legal education (either Russian or a foreign one that is recognized in Russia).26 The parties, however, may agree that this requirement can be satisfied by a co-arbitrator instead of the chairperson.

Most of the changes introduced by the new laws will take effect on 1 September 2016. The Russian government will have three months thereafter to establish the procedure for obtaining authorizations and depositing the rules of arbitral institutions with the relevant federal executive authority. Within one year of that, arbitral institutions that failed to obtain the authorization will be prohibited from administering arbitrations in Russia.

B. Cases

B.1 Asymmetrical Dispute Resolution Clause Enforced in Russia

The Court of Appeal upheld an asymmetrical dispute resolution clause that entitled both parties to refer the case to LCIA arbitration, but provided only the claimant (the “Bank”) with a right to start an action before any state court of competent jurisdiction (in this case, the Russian state courts) at any time before it appoints an arbitrator.27

The court of first level terminated proceedings with reference to a valid arbitration agreement between the parties and held, among other matters, that the provisions enabling the Bank to sue in any competent court were invalid as violating the balance of the parties’ interests.28 The Court of Appeal reversed the decision.29 The court found no evidence that the challenged provisions violated either English or Russian laws. The court therefore held that the Bank could file a lawsuit with any competent court, including the Rostov Region Arbitrazh Court, and sent the case for retrial to the first level court.

This decision provides some hope that state arbitrazh (commercial) courts in Russia may return to their earlier practice of upholding asymmetrical clauses.30 This practice was discontinued after Russia’s highest court in 2012 invalidated such clauses as violating the Russian law principle of equality of the parties and the balance of the parties’ interests.31

B.2 Award Partially Enforced Despite Error by Tribunal

The court partially enforced an award issued on 31 May 2013 by the Maritime Arbitration Commission at the Chamber of Commerce of the Russian Federation (“MAC Award”), holding that the remaining part was contrary to Russian public policy.32

The MAC Award failed to take account of an unconditional franchise agreed upon in the contract, though the relevant arguments were voiced by the parties and reflected in the descriptive part of the Award. The respondent applied to the tribunal to correct the MAC Award. The MAC Tribunal admitted that it made a mistake by not subtracting the franchise amount and issued an Additional MAC Award, reducing the amount awarded and changing the allocation of arbitration costs accordingly. The claimant applied to Moscow Arbitrazh Court to set aside the Additional MAC Award33 and, separately, for a writ of execution of the MAC Award. In the first case, the Additional MAC award was set aside due to violation of the arbitration procedure.34 In the second case, the first level court refused to enforce the MAC Award,35 but the cassation court reversed the decision.36

However, the Supreme Court disagreed with both first level and cassation courts and issued a writ of execution for partial enforcement. The Supreme Court held that the part of the Award concerning the unconditional franchise could not be enforced, as no legal certainty had been established by the Award regarding relations between the parties in respect of the franchise.37 The claimant’s further appeal was refused.38

B.3 Arbitration Clause Must Be Legally Compliant When Concluded

The Constitutional Court of Russia issued a decision reflecting the recent trend of Russian courts to oppose the conducting of arbitration by so-called “pocket arbitration courts,” which are created and subsidized by various companies, appearing as a party to arbitration under the rules of arbitration courts they themselves created.39

Road-construction Cooperative Society No. 956 (the “Cooperative”) applied to the Constitutional Court after the dispute against it was resolved by state arbitrazh (commercial) courts on the merits despite the arbitration clause in the contract. The courts took into account that at the time of concluding the arbitration clause, one of the managers of the Cooperative was at the same time the chairperson and arbitrator of the arbitration court, as well as a member of the board of the organization that established the court. The state courts ruled that this affiliation resulted in the breach of the guarantee of objective impartiality40 and led to the violation of the right to a fair trial by violating the equality and autonomy of the parties. In doing so, the courts dismissed the arguments by the Cooperative that: (1) no affiliation existed at the time of resolving the case; and (2) the other party knew of the affiliation when entering into the contract with the Cooperative.41 The courts noted that they must check for a lack of objective impartiality not only at the time of resolving the case, but also at the time of concluding the arbitration agreement itself.

The Cooperative, in its application to the Constitutional Court, challenged the provisions of the law on domestic arbitration courts insofar as those allowed courts to: (i) check the compliance of the actual procedure with the principles of arbitration proceedings not at the time after the dispute arose or in the course of the dispute, but at the time the arbitration agreement was concluded; and (ii) establish a violation of guarantees of objective impartiality of the arbitration court, and hence the breach of the right to a fair trial, not on the facts of a particular dispute, but on facts only existing before the dispute arose.

The Constitutional Court ruled that when a party is relying on the existence of the arbitration agreement as a defense against trial on the merits and the court is obliged to examine whether the arbitration agreement is valid, enforceable and capable of being performed, this includes, among other things, examining the compliance of the arbitration agreement at the time of its conclusion with all imperative legal provisions.

B.4 No Merits Review When Assessing Public Policy Compliance

In this case, Czech Export Bank (CEB) applied for enforcement of a foreign arbitral award42 granting the recovery of the assignment payment under an assignment contract with Mezhtopenergobank (the “Debtor Bank”).43 The first level court refused enforcement. The court found that the Debtor Bank exercised its right to retroactive assignment in the contract, and CEB failed to give effect to this right, filing instead for arbitration in the Czech Republic. In the court’s view, the initiation of arbitration by CEB amounted to an abuse of rights; thus, the resulting award contradicted the public policy of the Russian Federation. The trial court also accepted the respondent’s arguments that the transaction was invalid since it contradicted imperative rules of Russian banking legislation.

The cassation court reversed this decision and held that the effect of retroactive assignment was already considered by the tribunal, and added that the lower court was not entitled to review the award on the merits.44 The cassation court further stated that claims for invalidity of the assignment contract were dismissed in an earlier case by the respondent’s shareholder, and therefore, these findings were to be taken into account as both parties participated in that case.45

Despite the guidance given by the cassation court, the first level court at retrial refused enforcement again. It relied on the same arguments as in the first round, and ruled that the earlier case did not have any preclusive effect, as it invoked different grounds of invalidity. In November 2015, the cassation court reversed the decision and granted the enforcement.46 It relied on the Supreme Arbitrazh Court’s guidance on applying public policy,47 stating that the courts are not entitled to review the award on the merits when assessing whether enforcement of the award will entail a violation of public policy. Execution of this decision is currently suspended pending final cassation appeal proceedings at the Supreme Court.48

B.5 Arbitral Tribunal’s Right to First Rule on Its Jurisdiction Upheld

In this case, a state company, Russian Automobile Roads (RAD) filed a claim in Russian state court against Unified Toll Systems LLC for the recovery of contractual penalties under a long-term owner-operator contract.49 The respondent invoked the existence of an arbitration clause in the contract to ask for termination of the proceedings in the state court. The claimant objected, stating that neither contracting party at the moment the dispute arose met the requirements of the ICA Law for submission to international commercial arbitration. The parties were indeed entitled to resolve their dispute at the time of concluding the contract because the respondent was, at the time, a foreign-owned company. As the respondent no longer had this status, the arbitration clause could not be invoked.

The court dismissed these arguments and stated, among other matters, that the issue of whether the arbitral tribunal has jurisdiction to resolve the dispute is to be decided by the arbitral tribunal, with the party able to challenge the findings in court.
50 The appeal court upheld the decision.51 This case is to be welcomed as a case upholding the arbitral tribunal’s right to rule on its jurisdiction, thus demonstrating a pro-arbitration position.

C. Costs in International Arbitration

C.1 Allocation of Costs

The New ICA Law (like its predecessor) lacks special provisions on the allocation of arbitration costs. The New ICA Law stipulates only an obligation of the arbitral tribunal to include the amount of arbitration costs and their allocation between the parties in the arbitral award. Taking into account the lack of statutory regulation and the basis of arbitration proceedings in the agreement of the parties, the tribunals have a wide discretion when allocating costs. At the same time, as a matter of practice, “the costs follow the event” prevails, unless the winning party has abused its procedural rights or costs are excessive and unreasonable.

Thus, the Rules of ICAC52 entitle the winning party to be compensated for ICAC’s arbitration fee (consisting of its administrative costs and the fees of the tribunal) as well as any additional expenses (expenses of arbitrators, experts, etc.)53 The Rules also entitle the winning party to request compensation for its legal representation costs.54 At the same time, the ICAC Rules have provisions penalizing a party that acts unreasonably and in bad faith when exercising its procedural rights.55 The tribunals, in practice, seek guidance from the practice of state courts, as in the past, state courts took a very conservative approach to reimbursing legal costs (although this practice is changing).

C.2 Security for Costs

Article 17 of the ICA Law entitles the tribunal to order those interim measures in relation to the subject matter of the dispute that it deems necessary. However, in the New ICA Law, the link to the subject matter of the dispute has been removed.56 Therefore, there is no restriction on the type of interim measures to be adopted in arbitration proceedings, and theoretically, the tribunal may order security for costs. However, as a matter of practice, security for costs is never ordered by tribunals sitting in Russia. Since such orders are not enforceable through the Russian court system, parties see no benefit in applying for them.

C.3 Recovery of Costs

Both tribunals and state courts consider outside counsel’s time charges to be recoverable. Under Russian procedural law, the party claiming legal costs has to support their amount, their relevance to the case and the fact that they were incurred.57 When assessing the relevance of legal services, the courts consider whether the costs were borne in relation to a particular case. For example, courts view the time spent on “researching court practice” as not relevant to representation, because a qualified legal professional is supposed to already possess such knowledge.58 Likewise, the courts dismiss claims for the recovery of costs on consultations rendered before the institution of the proceedings. At the same time, costs incurred in the course of collecting evidence before initiating the proceedings can be accepted if those were necessary for exercising a right to trial and the evidence was relevant and admissible.59 The costs for complying with the mandatory pre-trial procedure provided for in the law or the contract are also recoverable.60

Russian procedural law entitles the winning party to reimbursement of costs “within reasonable limits.”61 Unless the other party asks the court to reduce the amount on the basis that the costs are excessive, and provides evidence, the court is not entitled to reduce costs, except for cases when the costs are clearly unreasonable (excessive) based on the evidence in the case file.62 Reasonable costs are considered to be those that are usually paid for a comparable service.63

The CAP contains no restrictions on the type of legal costs. When assessing whether a particular type of costs may be awarded, the courts consider the nature of the procedural steps that entailed the costs, and dismiss the claims if those steps were unreasonable and excessive.64 The costs of the party’s in-house counsel and other members of staff in practice are not recoverable because representation of the party is considered to be part of their employment duties.65 Theoretically, the courts may award the costs of overtime payments to members of a party’s staff, but we are not aware of any such cases.

The costs must also be incurred by a party to the proceedings. Thus, if the legal fees are paid by the parent company, they are not recoverable, unless assigned to the subsidiary that is party to the proceedings. However, if a third party has actually incurred a party’s legal costs based on some contractual arrangement with the party, then such costs may be recovered.66 One needs to substantiate the costs incurred by providing back-up documents, usually including an agreement for legal services, invoices, detailed reports on the services rendered, acts of acceptance and proof of payment. Both courts and tribunals may dismiss claims where a party has paid only part of the legal fees due to its legal counsel.67

There is no restriction under the New ICA Law on the awarding of “success fees.” ICAC awards follow the approach of the European Court of Human Rights in this regard and awards the parties not only the amounts they have actually paid to their representatives, but also the costs to be incurred by them in the future, once the tribunal find the costs to be reasonable and arising out of a valid obligation.68 State courts’ practices in this regard are not uniform. On the one hand, the Supreme Arbitrazh Court ruled that success fees may be awarded to a party provided that these costs were actually incurred by that party and were reasonable.69 At the same time, in a number of cases, the courts refused to enforce arrangements for additional success fee payments, interpreting these as bonuses agreed between the party and its legal counsel without any basis in terms of additional services. Such fees cannot be recovered from a party that has not entered into such an arrangement.70

  1. Vladimir Khvalei is a partner in Baker & McKenzie’s Moscow office and heads the firm’s CIS Dispute Resolution Practice Group. Mr. Khvalei is Vice-President of the ICC International Court of Arbitration, a member of the LCIA and Chairman of the Board of the Russian Arbitration Association.
  2. Irina Varyushina is a professional support lawyer in Baker & McKenzie’s Moscow office.
  3. Russian Federation Law N 5338-1, adopted on 7 July 1993.
  4. Federal Law No 382-FZ.
  5. Article 2 of Federal Law No 409-FZ.
  6. Article 1 of the ICA Law.
  7. Article 1 of the New ICA Law defines the circumstances in which parties may refer to international arbitration civil law disputes arising out of foreign economic activities in the following cases.
  8. New ICA Law, Article 17.
  9. “New laws,” in this context, includes not only the New ICA Law and the New Law on Domestic Arbitration, but also changes made to the Code of Arbitrazh Procedure (CAP), Code of Civil Procedure and other laws within the framework of the arbitration reform.
  10. New ICA Law, Article 16 (3) and Article 34 (1).
  11. Article 9 of Federal Law No 409-FZ: CAP, redrafted Article 225.1 (2).
  12. CAP, redrafted Article 225.1(3-4). Thus, corporate disputes (with certain exceptions) are to be resolved in institutional arbitration in Russia under special rules for corporate disputes.
  13. New ICA Law, Article 7 (8).
  14. International Commercial Arbitration Court and Maritime Arbitration Commission at Russia’s Chamber of Commerce and Industry (ICAC and MAC, respectively) do not require any such authorization.
  15. An advisory body to be formed at the Ministry of Justice and consisting of representatives of state authorities, trade chambers as well as representatives of legal, scientific and business communities.
  16. For detail see New Law on Domestic Arbitration, Article 44 (8).
  17. The New Law on Domestic Arbitration does not establish any criteria to determine when a foreign arbitral institution can be considered to have a reputation that is “recognized worldwide.”
  18. New Law on Domestic Arbitration, Article 44(3).
  19. New Law on Domestic Arbitration, Article 44 (3).
  20. New ICA Law, Article 13 (3).
  21. New ICA Law, Article 14 (2).
  22. New ICA Law, Article 16 (3).
  23. New ICA Law, Article 34 (1).
  24. New ICA Law, Article 6. For arbitrations under the Rules of the ICAC and the MAC the default appointing authority remains the President of the Russian Chamber of Commerce.
  25. New ICA Law, Article 35 (3).
  26. The parties may exclude the applicability of such criteria in their arbitration agreement.
  27. Deutsche Bank AG v. Razdolje, Rassvet and Razvilenskoye, case number А53-17338/2014, case file at:
  28. Ruling of Rostov Region Arbitrazh Court dated 27 November 2014.
  29. Decision of the 15th Court of Appeal dated 12 March 2015.
  30. ING Bank v. Petrokommerz (2009), case file at:; Red Barn Capital LLC v. Petrokommerz (2009), case file at:; Surgutneftegazbank v. Financial Leasing Company (2010), case file available at:
  31. Ruling of Supreme Arbitrazh Court No. 1831/12 dated 19 June 2012, Russian Telephone Company v. Sony Ericsson Mobile Communications Rus LLC, case file at: We reported this case in the 2012/2013 Yearbook at pp. 370-373.
  32. Korradino Corporation Ltd. v. Russian Insurance Centre, case А40-274/14-50-5, case file at:
  33. Case А40-132569/2013, case file at:
  34. The violation consisted in the fact that it was issued upon the MAC Tribunal’s own initiative without hearing the parties. See Resolution of Arbitrazh Court of Moscow Circuit dated 26 March 2014, Ruling of Supreme Arbitrazh Court No VAS-8758/14 dated 30 June 2014
  35. Moscow Arbitrazh Court Ruling dated 25 December 2013.
  36. See Resolution of Arbitrazh Court of Moscow Circuit dated 23 July 2014. It is noteworthy, that the hearing in cassation took place after the final decision in the first case for setting aside the Additional Award.
  37. Ruling of the Supreme Court dated 24 February 2015.
  38. Ruling of the Supreme Court dated 3 July 2015.
  39. Constitutional Court Ruling dated 23 April 2015 No. 940-O Upon an Application by Road Construction Cooperative Society No. 956.
  40. This unfortunate term was introduced by Russian courts to mean “independence.”
  41. See case file at: for a detailed case history.
  42. Award dated 21 February 2014 in case No. Rsp 140/13 issued by Arbitration Court at the Economic and Agrarian Chamber of the Czech Republic.
  43. Czech Export Bank v. Mezhtopenergobank, case file at:
  44. Resolution of Arbitrazh Court of Moscow Circuit dated 5 March 2015.
  45. Skartos v. Mezhtopenergobank and Czech Export Bank, case file at:
  46. Resolution of Arbitrazh Court of Moscow Circuit dated 18 November 2015.
  47. Information Letter No. 156 dated 26 February 2013 “Review of court practice by arbitrazh (state commercial) courts in applying the public policy provision as grounds for refusing to enforce foreign court decisions and awards.”
  48. Ruling of the Supreme Court dated 1 December 2015 on the stay of enforcement of a court judgment.
  49. Russian Automobile Roads v. Unified Toll Systems, case file at:
  50. Ruling of Moscow Arbitrazh Court of 16 April 2015.
  51. Resolution of the 9th Court of Appeal dated 16 June 2015.
  52. International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation.
  53. §§6-7 of Regulations on Arbitration Fees and Expenses (Enclosure to ICAC (Moscow) Rules).
  54. §9 of Regulations on Arbitration Fees and Expenses (Enclosure to ICAC (Moscow) Rules).
  55. §§10 of Regulations on Arbitration Fees and Expenses (Enclosure to ICAC (Moscow) Rules), §13, 30 of ICAC (Moscow) Rules.
  56. New ICA Law, Article 17 (1).
  57. Para. 10 of Resolution of the Supreme Court’s Plenary Session dated 21 January 2016.
  58. Resolution of Arbirazh Court of Moscow Circuit, 11 November 2015 in case N А40-157397/2013.
  59. Such costs may include those in connection with legalization of official documents, notary’s actions for securing evidence, or issuance of a power of attorney for a particular case. See Para. 2 of Resolution of the Supreme Court’s Plenary Session dated 21 January 2016.
  60. Para. 4 of Resolution of the Supreme Court’s Plenary Session dated 21 January 2016.
  61. Part 2 of Article 110 of the CAP.
  62. Para. 11 of Resolution of the Supreme Court’s Plenary Session dated 21 January 2016.
  63. The following is taken into account in assessing whether the costs are reasonable: the amount of claims filed, the dispute amount, complexity of the case, time requisite for preparation of procedural documents, duration of court proceedings, etc. The prominence of a person’s representative cannot justify higher costs. See Para. 13 of Resolution of the Supreme Court’s Plenary Session dated 21 January 2016.
  64. See Para. 32 of Resolution of the Supreme Court’s Plenary Session dated 21 January 2016.
  65. See Para. 11 of Information Letter of the Presidium of Supreme Arbitrazh Court No. 121, 05 December 2007.
  66. See Para. 5 of Information Letter of the Presidium of Supreme Arbitrazh Court No. 121, 05 December 2007.
  67. Para. 4 of Information Letter of the Presidium of Supreme Arbitrazh Court No. 121, 05 December 2007.
  68. ICAC Cases 104/2014 and 250/2013.
  69. Para. 6 of Information Letter of the Presidium of Supreme Arbitrazh Court No. 121, 05 December 2007; Resolution of the Presidium of Supreme Arbitrazh Court, 04 February 2014 No 16291/10.
  70. Overview of Supreme Court’s Court Practice No. 2 (2015), 26 June 2015.