The English Commercial Court set aside P&ID's arbitral awards against Nigeria on 23 October 2023, holding they were obtained by fraud.

Why this label

The judgment of 23 October 2023 is [2023] EWHC 2638 (Comm)^S5. The UK Supreme Court's 2025 judgment states that Knowles J set aside the awards under section 68 of the Arbitration Act 1996 and that the awards were obtained by fraud^S2. The judgment finds that payments in December 2009 and March 2010 were bribes paid on behalf of P&ID^S1. The Court of Appeal summarised the findings on false evidence and retained legal documents in June 2025^S6. The later appeals concerned only the currency of costs and findings about a lawyer for P&ID^S2S6. No record read shows an appeal against the set aside itself.

Current procedural position

Awards set aside by the Commercial Court on 23 October 2023^S5. Costs currency appeals dismissed by the Court of Appeal on 12 July 2024 and the UK Supreme Court on 22 October 2025^S2. No appeal against the set aside found as of October 2026.

Evidence score: 95 of 100

The score grades how well the record establishes this assessment. It is not a score of Process and Industrial Developments Limited. Score = source authority + directness + corroboration + procedural accuracy + currency + reproducibility.

Timeline

1. 23 October 2023Commercial Court sets aside the awards^S5S1
2. 8 December 2023Knowles J orders costs paid in sterling^S2
3. 12 July 2024Court of Appeal dismisses the costs currency appeal^S2
4. 10 June 2025Court of Appeal refuses permission to appeal findings about a lawyer for P&ID^S6S7
5. 22 October 2025UK Supreme Court dismisses P&ID's appeal^S2

Related cases

• The Federal Republic of Nigeria v Process and Industrial Developments LimitedHigh Court of Justice, Business and Property Courts of England and Wales, Commercial Court. Arbitration. CL-2019-000752 and CL-2018-000182, [2023] EWHC 2638 (Comm).Stage: Awards set aside. Costs appeals dismissed^S2S5
  • 10 June 2025 Court of Appeal refuses permission to appeal findings about a lawyer for P&ID, [2025] EWCA Civ 715^S6S7
  • 22 October 2025 UK Supreme Court dismisses appeal, [2025] UKSC 36^S2

Revision history

• 25 October 2026 Assessment first published with label Supported.

Have a record that changes this assessment? See corrections and responses.

Sources

1. S2Tier A Process & Industrial Developments Limited (Appellant) v The Federal Republic of Nigeria (Respondent)UK Supreme Court. Court judgment. 22 October 2025.Records the awards, the set aside for fraud and the costs appeals. The appeal concerned only the currency of costs.Link working, checked 25 October 2026
2. S1Tier A The Federal Republic of Nigeria v Process & Industrial Developments Limited [2023] EWHC 2638 (Comm)High Court of Justice, Commercial Court, via The National Archives. Court judgment. 23 October 2023.Supports the award amount and the findings on bribes at paragraphs 10, 40, 170 and 177. The conclusion section could not be retrieved in the text read for this review.Link working, checked 25 October 2026
3. S3Tier C UK court overturns $11 billion damages bill for collapsed gas deal against NigeriaPeoples Gazette (Olumayowa Samuel, citing Reuters). Press report. 23 October 2023.Reports the ruling, the judge's words and P&ID's denial. It is not a court record.Link working, checked 25 October 2026
4. S5Tier A The Federal Republic of Nigeria -v- Process & Industrial Developments LimitedJudiciary of England and Wales. Court judgment. 23 October 2023.Judgment page giving the date, judge, citation and claim numbers. It holds no findings in the text read.Link working, checked 25 October 2026
5. S6Tier A The Federal Republic of Nigeria v Process and Industrial Developments Ltd & AnorCourt of Appeal of England and Wales (Civil Division), via The National Archives. Court judgment. 10 June 2025.[2025] EWCA Civ 715. Paragraph 2 summarises the 2023 findings on false evidence, bribes during the arbitration and retained legal documents. The application concerned findings about a lawyer who acted for P&ID.Link working, checked 25 October 2026
6. S7Tier D Court of Appeal rejects appeal to remove critical findingsEssex Court Chambers. Academic paper. 10 June 2025.Chambers note reporting that the Court of Appeal refused permission to appeal findings about a lawyer for P&ID. It is not the judgment.Link working, checked 25 October 2026

Other claims about Process and Industrial Developments Limited

• Supported89
  The Commercial Court found in October 2023 that P&ID's side gave knowingly false evidence in the arbitration, kept paying bribes during it and improperly retained Nigeria's internal legal documents.
  Court filing, 23 October 20235 records citedFraud
• Outdated96
  Arbitral awards required Nigeria to pay P&ID US$6.6 billion plus 7% interest, a liability reported to exceed US$11 billion.
  Press report, 23 October 20233 records citedCorporate status
• Contradicted91
  P&ID denied paying bribes and blamed the failure of the gas deal and Nigeria's arbitration loss on institutional incompetence.
  Press report, 23 October 20234 records citedBribery
• Supported65
  Nigeria's EFCC said on 19 September 2019 that the Federal High Court in Abuja convicted two P&ID directors on eleven counts and ordered P&ID wound up in Nigeria with its assets forfeited.
  Regulator statement, 19 September 20191 record citedFraud