Contract analysis

1. V&E has not challenged the freezing injunction separately. The opposition is directed solely at the enforcement application, and the injunction accordingly remains undisturbed.

2. The court has now set a timetable for the reply: KM&P's response is due within 21 days from today, i.e., by **Wednesday, 9 October 2024**. A hearing is likely to be listed in late October.

3. It is notable that KMH has not raised any ground under Article V(1)(a) (invalidity of the arbitration agreement) or Article V(1)(c) (award beyond the scope of submission to arbitration). These are typically among the stronger grounds available, and their absence is significant.

4. The opposition makes no reference to, and does not acknowledge, the parallel English Commercial Court proceedings (Claim No. CL-2024-000487), in which permission to enforce the award was granted on 2 August 2024 by Mr. Justice Ashworth and in which a worldwide freezing order up to £108,600,000 remains in force.

5. As you will be aware, KMH's application to set aside the award under sections 68 and 69 of the Arbitration Act 1996 was filed on 19 August 2024 in England and has not yet been determined. The Cyprus court may wish to be informed of this parallel challenge, and I would welcome your views on whether and how we should address this in our reply. In my assessment, the set-aside application is unlikely to succeed, but i