Anti-suit injunction

The claimant brought an action in England claiming to be indemnified by the defendant, pursuant to three contracts of reinsurance. After several months of negotiations in respect of the English claims, it launched a claim in New York, allegedly without informing the defendant. The defendant, having become aware of the New York claim, applied for an anti-suit injunction. The claimant applied for a stay of the English proceedings pending the US court’s determination of Equitas Insurance Ltd’s motions for a stay. The court ruled that it was settled law that the English court should favour its own conflict of law rules and, under those rules, it was overwhelmingly likely that English law governed the formation and meaning and effect of the reinsurance contracts. It was settled law that where a claimant had brought a claim against the same defendants for essentially the same relief arising out of the same facts in two jurisdictions, then, absent special circumstances, it would be wrong for the court to grant