Petersen Energia Inversora, S.A.U. & Ors v The Republic of Argentina [2026] EWHC 1492 (Comm)

[2026] EWHC 1492 (Comm)Case No CL-2024-000129
IN THE HIGH COURT OF JUSTICE
THE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES
KING'S BENCH DIVISION
COMMERCIAL COURT
Venue Rolls Building, Royal Courts of JusticeDate 17 th June 2026
London
THE HON MR JUSTICE ROBIN KNOWLES CBE
Between:ClaimantsPETERSEN ENERGIA INVERSORA, S.A.U.ClaimantPETERSEN ENERGIA, S.A.U.ClaimantETON PARK CAPITAL MANAGEMENT, L.P.ClaimantETON PARK MASTER FUND, LTD.ClaimantETON PARK FUND, L.P.ClaimantTHE REPUBLIC OF ARGENTINADefendant
Anton Dudnikov KC and Akash Sonecha (instructed by Pallas Partners LLP) for ClaimantsDavid Railton KC, Sebastian Isaac KC and Jacob Turner (instructed by Enyo Law LLP) for DefendantHearing Hearing date:19 May 2025
Approved JudgmentThis judgment was handed down remotely at 14:00 on 17 June 2026 by circulation to the parties or their representatives by e-mail and by release to the National Archives.
[1]On 15 September 2023 the United States District Court for the Southern District of New York (Senior United States District Judge Loretta A. Preska) entered judgment for the Claimants (“the Claimants”) on claims for breach of contract against the Defendant (“Argentina”). The judgment was for damages and interest in a sum exceeding US$16 billion. The amount was determined after summary judgment had been granted on liability.[2]Argentina appealed. In a decision dated 27 March 2026 the United States Court of Appeals for the Second Circuit (Judges Chin and Robinson; Judge Cabranes dissenting) reversed the judgment of Judge Preska on the Claimants’ breach of contract claim against Argentina. A dismissal by Judge Preska of promissory estoppel claims against Argentina was affirmed. The case was remanded to the District Court “for further proceedings consistent with the opinion of” the appellate court.[3]On 8 May 2026 the Claimants petitioned the Second Circuit to grant a rehearing en banc. The petition for rehearing included a contention by the Claimants to the effect that the matter is important to the United States capital markets.[4]The matter has reached the Commercial Court of England & Wales because on 4 March 2024 the Claimants issued a claim for the recognition and enforcement of the judgment of Judge Preska. Argentina commenced a challenge to the jurisdiction of the English Court, including to an order made by Bryan J on 8 March 2024 permitting service on Argentina of the claim for recognition and enforcement.[5]Argentina also sought a stay of the claim for recognition and enforcement, without prejudice to its challenge to jurisdiction. The parties agreed in January 2025 that the stay application should be considered first. They then agreed an order (made by Dias J on 17 July 2025) by which Argentina withdrew the stay application on terms of certain undertakings by the Claimants and Burford Capital Limited (“Burford”) to the Court.[6]The undertakings included an undertaking that in the event that Argentina’s appeal against Judge Preska’s judgment was “finally resolved (i.e. without any further appellate recourse being available) on terms overturning the decision on liability”, the Claimants and Burford would pay certain costs and the Claimants would consent to an order setting aside the claim for recognition and enforcement. There was also an undertaking in respect of costs in the event that Argentina’s appeal against the damages award in Judge Preska’s judgment was “finally resolved (i.e. without any further appellate recourse being available)” and as a consequence the claim for recognition and enforcement was set aside.[7]At the time of oral argument before this Court, the Second Circuit had not yet announced whether it would grant a rehearing en banc. Further the Second Circuit had not yet issued a “mandate” (by which jurisdiction formally transfers from the Second Circuit to the United States District Court) and the United States District Court had stayed proceedings pending receipt of the mandate. The parties have since informed the Court that the Second Circuit has declined to grant a rehearing en banc. In that event the Claimants had indicated an intention to seek to bring the case before the United States Supreme Court. The Second Circuit issued the mandate on 10 June 2026.

The position of the parties at this point

[8]In light of the decision of the Second Circuit, neither party invites the Commercial Court to determine the challenge to the jurisdiction of the English Court at this point.[9]Argentina takes this position:
“The sole question for the Court at this hearing is what should happen now. The Republic’s position is that the Claim is now unsustainable in light of the Second Circuit Judgment, such that service should immediately be set aside and the Claim dismissed. It applies to amend the Jurisdiction Challenge to rely on the Second Circuit Judgment as a new and discrete ground (referred to as “Ground A”) for the relief sought, and for that Ground to be determined now. The Republic’s position is simple. The Claim for recognition and enforcement was premised on the existence of a final and conclusive foreign judgment. As a result of the Second Circuit Judgment, the SDNY Judgment [of Judge Preska] is no longer final and conclusive. There is accordingly no basis for these proceedings, or for the alleged jurisdiction of the Court over the Republic which the Claimants have sought to invoke. …”
The Republic’s position is simple. The Claim for recognition and enforcement was premised on the existence of a final and conclusive foreign judgment. As a result of the Second Circuit Judgment, the SDNY Judgment [of Judge Preska] is no longer final and conclusive. There is accordingly no basis for these proceedings, or for the alleged jurisdiction of the Court over the Republic which the Claimants have sought to invoke. …”[10]Argentina explained the proposed amendment as follows:
“By an application filed on 27 April 2026 … the Republic seeks permission to amend its original application notice in respect of the jurisdiction challenge in order to add a new basis for permission to serve out being set aside and the claim being dismissed, namely the impact of the Second Circuit Judgment (referred to as the “Ground A Jurisdiction Challenge”, to distinguish it from the original grounds, referred to as the Ground B Jurisdiction Challenge …). If permission is granted, the Republic further seeks, as a matter of case management, the determinationof the Ground A Jurisdiction Challenge. This is a short point, which can and should be resolved now.”
[11]For their part, the Claimants invite the Court to stay the claim for recognition and enforcement and refuse the application to amend. Their application to stay was issued on 15 April 2026.

Discussion and decision

[12]The availability or commencement of an appeal against the judgment of Judge Preska did not disentitle the Claimants from seeking recognition and enforcement of the judgment in England & Wales. That is common ground between the parties, based on an appreciation that unless and until set aside on appeal, a judgment is final and conclusive.[13]The Second Circuit has reversed the judgment. The judgment of Judge Preska is no longer final and conclusive. A claim for recognition and enforcement could not be commenced now. However, the available appeal process in the United States has not concluded.[14]The question for the Commercial Court is to decide what the interests of justice require at this point in relation to the claim for recognition and enforcement. This may also be viewed as a matter of appropriate case management of that claim.[15]In connection with the amendment application and the application to set aside the order permitting service on Argentina of the claim for recognition and enforcement, the parties discussed Erste Group Bank AG, London Branch v JSC ‘VMZ Red October’ & Others [2015] EWCA Civ 379; [2015] 1 CLC 706 at [44]-[45], and ISC Technologies Ltd v Guerin [1992] 2 Lloyd’s Rep 430 at 434. The decisions address the question whether an application to set aside an order is to be considered as at the time of making the order or as at the time of the application to set aside. I do not consider that the decisions assist in the present case where the Court is addressing the question of how it should proceed where a judgment capable (subject always to the arguments raised by the parties) of sustaining a claim for recognition and enforcement has since been reversed.[16]In connection with the application for a stay of the claim for recognition and enforcement, the parties also discussed Reichhold Norway ASA v Goldman Sachs International[1999] EWCA Civ 1703; [2000] 1 WLR 173, 186 and Athena Capital Fund SICAV-FIS SCA v Secretariat of State for the Holy See [2022] EWCA Civ 1051; [2022] 1 WLR 4570 at [59]. These decisions address the question whether a case management stay pending the outcome of proceedings in another jurisdiction will only be in the interests of justice in rare and compelling cases. The decisions were not addressing the recognition and enforcement by the English Court of a judgment of that other jurisdiction.[17]However in Motorola Solutions Inc v Hytera Communications Corporation Ltd [2025] EWCA Civ 1667 the Court of Appeal considered what should happen to an order made by the Commercial Court recognising and enforcing a judgment for damages of a United States District Court where a United States Court of Appeals (there, for the Seventh Circuit) had since overturned the damages award and remitted the case to the District Court for a further assessment of damages. The Court of Appeal (of England & Wales) granted a stay, holding that revocation was not at that stage appropriate.[18]The Court of Appeal gave these reasons (at [128] to [130]):
“First, it is undesirable in the context of this hotly contested litigation, which has already been the subject of multiple appeals here and in the US, to repeatedly grant and revoke final judgments. The rapidly changing circumstances of litigation of this kind are better catered for by the grant of appropriate stays under CPR Part 40.8A, if necessary on terms as to security, designed to avoid injustice to either party. It will be soon enough, when Motorola’s entitlements under US judgments are clear, for the English Judgment to be revoked and replaced with a final judgment in the appropriate amount. Secondly, this is not, as we have said, an unusual or exceptional situation. Our law entitles foreign judgment creditors, holding a final first instance judgment, to enforce it in England & Wales, even whilst it is under appeal. It is undesirable, in this relatively commonplace situation, for the English Court to have to react, in terms of final judgments, to the twists and turns of the foreign judicial process. There are better ways of achieving just interim solutions. Thirdly, we do not underestimate the commercial consequences for any commercial entity, including Hytera in this case, of having large judgments stand against them, when they are likely eventually to need to be revoked or varied. But that is the consequence of our private international law that allows final foreign first instance judgments to be enforced whilst under appeal abroad, subject only to a stay in appropriate circumstances. Any interested observer can have the situation fully explained. This judgment will serve that purpose for Hytera's trading partners. It is not indicative of requiring, as we have now said twice, the English court to repeatedly grant and revoke final judgments, which have been granted, in the first place, only for the purpose of enforcement.”
[19]Each case must be decided on its own facts and circumstances. Nonetheless the decision of the Court of Appeal offers guidance on approach. The points made by the Court of Appeal in Motorola in the passage quoted above shows the Court prepared to use an interim stay, even though there was no final and conclusive judgment in the United States as matters then stood. And that was in circumstances where, in contrast to the present case which has not reached the stage of any order for recognition or enforcement, matters had reached the point of a decision by the English Court to recognise and enforce.[20]I cannot accept that there is serious prejudice to Argentina of allowing what is simply an undecided claim for recognition and enforcement to remain for the time being, even where the judgment in the United States that stands reversed was of the magnitude it was and against a state. The fact is that the judgment still stands reversed, and an undecided claim for recognition and enforcement does not mean much.[21]There is no need for any material costs to be incurred by either party in the proceedings for recognition and enforcement for the duration of any stay. It is true that a stay would in practice postpone the point at which Argentina would be able to seek recovery of its costs. It is possible that the Claimants, whose ability to pay costs pre-dating the undertaking from Burford is already in some doubt, may become even less able to pay as time passes. However, that is a modest point in the scheme of the present case in my assessment.[22]On the other hand, I am not to be taken as considering that any prejudice to the Claimants by the possibility of having to start again with a claim for recognition and enforcement would be serious prejudice in the context in which that would occur. True there would be cost, but work that had been done would not be lost and could be used again, and the cost in the context of the overall sums at issue would be almost immaterial. Delay could be managed.[23]In the end, things are finely balanced, but the balance is just in favour of leaving things as they are for the time being by ordering a stay. That says nothing at all about the conclusions reached by Judge Preska or by the Second Circuit.[24]If the US Supreme Court declines to permit the Claimants to appeal, or the Claimants delay in prosecuting any appeal they may be permitted to bring by the US Supreme Court, the stay can be ended quickly. There will be a liberty to apply to allow matters to be considered further by this Court in the event of developments not anticipated at the time of this hearing or where otherwise appropriate.[25]Dealing with the matter in the way I have described, I would at this point allow the amendment application but not proceed now to determine the claim by reference to the new ground the amendment introduces. That, and other existing grounds, will be within the compass of the stay of the claim for recognition and enforcement.[26]For the avoidance of doubt, what I have said at paragraph 15 above in relation to the decisions in Erste Group Bank and in ISC Technologies is not intended to prevent the parties further discussing those authorities at any further hearing of or in connection with the claim for recognition and enforcement (including the application to set aside the order permitting service on Argentina of the claim for recognition and enforcement).