In Beograd Innovations Ltd v Somovidis [2025] EWHC 1182 (Comm), handed down on 27 May 2025, HHJ Pelling KC has dismissed a jurisdiction challenge by the defendant based on parallel Russian insolvency proceedings.

The claimant, Beograd, sued to enforce a Russian judgment worth around £14 million against Mr Somovidis in England. Mr Somovidis had also been made bankrupt in Russia in proceedings in which Beograd was his creditor and had proved for its debt.

Mr Somovidis argued that Russian bankruptcy law contained a principle preventing a creditor from pursuing its claim outside the bankruptcy (including abroad) and that the Court was bound as a matter of English law to give effect to that Russian law principle and permanently stay its proceedings.

The Court held that there was no rule of English law to that effect. A creditor who proves in a foreign bankruptcy does not become ‘bound’ by the law governing that bankruptcy and is not precluded from bringing separate enforcement proceedings in England. Instead, the only relevant principle is that of ‘modified universalism’, whereby the English court will lend assistance to foreign insolvency processes so far as it can do so in accordance with the ends of justice and English public policy. While that could in principle justify a stay of proceedings in an appropriate case, in this case there was no good reason to grant a stay, in particular because doing so would have made Mr Somovidis effectively judgment-proof in respect of any immovable property in England: such property did not form part of his bankruptcy estate and could never be recovered by his Russian bankruptcy trustee, as confirmed by the decision of the Supreme Court in Kireeva v Bedzhamov [2024] 3 WLR 1010. The Court also declined in any case to find that Russian law prohibited the pursuit of the English proceedings in those circumstances.

Alexander Milner KC and Joseph Leech appeared for Beograd, instructed by Ivan Gordienko and Alex Green of Steptoe International (UK) LLP.

A copy of the judgment is available here.