Trafigura PTE Limited v Société Nationale de Raffinage

Facts

The claimant, Trafigura PTE Limited, a Singapore-incorporated commodities trader, sold gasoil and gasoline to the defendant, Société Nationale de Raffinage (SONARA), an oil refining company 96% owned by the Republic of Cameroon, under a Sale Contract dated 6 October 2025. The Sale Contract was governed by English law and contained an exclusive jurisdiction clause in favour of the High Court in London at clause 23G, subject to an exception permitting arrest, attachment and other conservatory, interlocutory or interim actions in any court. Payment was to be made in part under an irrevocable letter of credit opened on 28 November 2025, issued by BGFI Bank Cameroun SA and confirmed by African Export Import Bank, itself governed by English law and subject to the exclusive jurisdiction of the High Court. Successive samplings of the gasoline cargo produced conflicting results and SONARA purported to reject the cargo on quality grounds on 24 December 2025, seeking to have the letter of credit suspended. On 4 February 2026 SONARA commenced proceedings in the Court of First Instance of Limbe, Cameroon, seeking suspension of payment. Robin Knowles J granted an interim anti-suit injunction on 1 April 2026 under section 37 of the Senior Courts Act 1981. Payment of EUR 6,492,254.79 was nevertheless made on 9 April 2026, yet the Limbe Proceedings were maintained.