On 26 May
2021, the French Court of Cassation ruled that the Central Bank of Libya was
allowed to make a third-party application to set aside the enforcement decision
of an award rendered in Cairo against the State of Libya. The matter was remanded
to the Paris Court of Appeal. The Paris court considered the central bank’s
standing hypothetical and declared the application inadmissible. Such a
restrictive assessment of the claimant’s standing makes unlikely any successful
third-party application against enforcement decisions of awards. It also reopens
the discussion on whether third-party applications against the award itself
should be allowed under French international arbitration law.