ANTI-SUIT INJUNCTIONS, ECHR AND THE PUBLIC POLICY DEFENCE

This article examines a specific injunctive remedy: the anti suit injunction. This is a discretionary judicial order directed at a private party, intended either to prohibit the initiation of proceedings in another forum or to compel the party to cease any proceedings already commenced in that forum under the threat of financial or personal sanctions. After outli ning the key judicial developments that have established the incompatibility of anti-suit injunctions with the European legal order, the analysis shifts to the impact of Brexit and the conflict with Russia on the issuance of such injunctions by courts. Within this framework, the article primarily focuses on the possibility of identifying a new legal basis for restricting the circula tion of anti-suit injunctions under the general clause of international public policy