Sibir Energy Ltd and other companies v Tchigirinski and others [2012] EWHC 1844 (QB), [2012] All ER (D) 80 (Jul)
It was established law that the court should be able to refuse an application which would otherwise meet the requirements of Art 6(1) of the Convention on Jurisdiction and the Enforcement of Judgments in Civil and Commercial Matters if there was clear evidence of collusion or abuse. Where, in terms of degree of collusiveness, the line should be drawn could only be answered by reference to the facts of a particular case.