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Paris Court of Appeal to Hear Final Challenge on Sulu Arbitration Award

Paris court's July 7 decision may end Sulu heirs' US$15B Sabah arbitration saga

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PARIS—The Paris Court of Appeal will on 7 July weigh what may be the final bid by heirs of the Sultan of Sulu to enforce a controversial US$15 billion arbitration over Malaysia’s Sabah, after courts across Europe tossed out the claim.

Manila, Philippine - July 02, 2025 -

Paris - On July 7, the Paris Court of Appeal will hear what is expected to be the final legal challenge in a dispute involving a nearly US$15 billion arbitration award tied to historical claims over Sabah, a Malaysian state on the island of Borneo.

The hearing follows multiple rulings across Europe rejecting attempts by individuals claiming to be heirs of the former Sultan of Sulu to enforce the award issued by Spanish arbitrator Gonzalo Stampa in 2022. Stampa was later convicted by a Spanish court for contempt and banned from acting as an arbitrator for one year.

At the heart of the case is an 1878 agreement between the Sultan of Sulu and European traders, which remains the subject of legal and historical debate.

Efforts to enforce the arbitration award have been dismissed in Spain, France, the Netherlands, and Luxembourg, with courts citing procedural irregularities, jurisdictional overreach, and the annulment of Stampa’s mandate by Spanish authorities.

With the upcoming Paris ruling, legal experts anticipate closure in a case that has tested the boundaries of international arbitration and sovereign immunity. Malaysian officials have expressed confidence that the Court of Appeal will reaffirm the inapplicability of arbitration to the 1878 agreement.

Despite legal setbacks, representatives of the claimants have signaled intentions to continue pursuing their case through alternative channels, although the path forward remains uncertain.

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Peter Peralta

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