The Paris Court of Appeal is set to hear what is widely anticipated to be the final legal challenge on July 7, 2025, in a long-standing dispute concerning a nearly US$15 billion arbitration award. The award is tied to historical claims over Sabah, a Malaysian state located on the island of Borneo.
This pivotal hearing follows a series of rejections by courts across Europe, including in Spain, France, the Netherlands, and Luxembourg, which have consistently dismissed attempts by individuals claiming to be heirs of the former Sultan of Sulu to enforce the controversial award. The award was initially issued in 2022 by Spanish arbitrator Gonzalo Stampa, who was subsequently convicted by a Spanish court for contempt and banned from acting as an arbitrator for one year.
At the core of the complex case is an 1878 agreement between the Sultan of Sulu and European traders, an accord that continues to be a subject of intense legal and historical debate. Courts in multiple jurisdictions have cited significant procedural irregularities, jurisdictional overreach by the arbitrator, and the annulment of Stampa’s mandate by Spanish authorities as reasons for dismissing the enforcement efforts.
Legal experts closely following the case anticipate that the upcoming Paris ruling will bring a definitive closure to a dispute that has significantly tested the boundaries of international arbitration and the principle of sovereign immunity. Malaysian officials have expressed strong confidence that the Paris Court of Appeal will uphold their position, reaffirming that the 1878 agreement is not subject to arbitration.
Despite the numerous legal setbacks, representatives for the claimants have indicated their intention to explore alternative avenues to pursue their case, though the specific path forward remains uncertain.
