DNZ v. DOA and DOB is a unanimous judgment of the Singapore International Commercial Court (SICC), issued on 9 January 2026 following Poland’s request to set-aside the Energy Charter Treaty (ECT) award in GreenX Metals v. Poland – a case involving allegations by an Australian company and its two UK subsidiaries that Polish authorities had obstructed the development of their coal-mining projects. Before the Court, Poland raised a total of five objections to the ECT award: three jurisdictional objections, pointing to the existence of an intra-EU dispute, the absence of a protected ‘investment’ and non-compliance with the ECT’s fork-in-the-road provision; one objection alleging breach of public policy; and a final objection alleging a breach of natural justice. The Court ultimately dismissed all objections and upheld the ECT award. The judgment is notable for its clear dismissal of the intra-EU objection and for aligning itself with the similar views of other, non-EU domestic courts. Additional notable findings of the Court include the dismissal of the applicability of the Salini criteria in nonICSID arbitrations and the reaffirmation of the narrow scope of the public policy ground for setting aside arbitral awards in Singapore.
European Investment Law and Arbitration Review