{"id":663110,"date":"2026-04-23T20:41:40","date_gmt":"2026-04-23T18:41:40","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/the-federal-republic-of-nigeria-v-jp-morgan-chase-na\/"},"modified":"2026-04-23T20:41:40","modified_gmt":"2026-04-23T18:41:40","slug":"the-federal-republic-of-nigeria-v-jp-morgan-chase-na","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/ru\/jurisprudences\/the-federal-republic-of-nigeria-v-jp-morgan-chase-na\/","title":{"rendered":"THE FEDERAL REPUBLIC OF NIGERIA v JP MORGAN CHASE NA"},"content":{"rendered":"
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MR. JUSTICE COCKERILL : Judgment on Permission to Appeal 1. Thank you very much. Mr.\u00a0Masefield, I\u00a0am not going to give you permission to appeal. While I\u00a0am grateful for the focus and clarity of your grounds, the fact that you have produced grounds (which is by no means always the case) and the courtesy with which the submissions have been made, I\u00a0do not regard either of the grounds as having real prospects of success. I\u00a0will deal with real prospect of success first before dealing briefly with the \u201csome other compelling reason\u201d ground. 2. Ground 1 concerns the 2011 fraud and by extension also the 2006 fraud. The primary submission is that I\u00a0misdirected myself on the law. This is done largely by reference to authority which was certainly not cited in closing and I\u00a0am not sure whether it was cited at all. Whether or not it was cited, I do not consider that there is real prospect of success in relation to this. 3. The proposed appeal really breaks down into a case on error of law, and a factual appeal. 4. On the error of law aspect, the authorities to which I\u00a0referred in the judgment were entirely conventional. The summary which I\u00a0then produced synthesising them, one might say summarises them rather in favour of the claimants than otherwise. It is not the case that I\u00a0actually took any of the tests from those cases and applied that test. The approach taken by me is not fairly summarised in my view in the application and certainly the submissions made on the law are not ones made to me at the time. 5. So far as the summary which I did use goes, the proposition that there needs to be a\u00a0fact tilting the balance in favour of fraud is effectively simply a\u00a0more specific way of re-stating the balance of probabilities test. You cannot win unless one side is more likely than the other; and that is effectively what is encapsulated in paragraph 209(1) and then in 209(4) of the judgment. And that is the test for which the Claimants contend. 6. As for the submission that I\u00a0erred in considering each fact seriatim before considering overall, there was no authority cited for the proposition that that is a\u00a0wrong thing to do; and this really feeds into the wider appeal, which is an appeal on the facts. That second aspect of the fraud appeal, although under cover of a\u00a0legal argument, really amounts to an argument that I\u00a0misevaluated the factual evidence. 7. For all that it is said that the Court of Appeal are more ready to look at this sort of question than they were in days of yore and that the factual findings they would need to do so quite expeditiously are there and that the issues are predominantly in the documents, so that it is not necessarily a\u00a0question best left to me, it remains the case that the Court of Appeal says again and again that complex questions of factual evaluation are best done by the trial judge. There is ample authority demonstrating their unwillingness to go behind such findings. 8. I\u00a0have listened carefully to the submissions made and with the best will in the world I\u00a0am not persuaded that this is a\u00a0case where be more than a\u00a0fanciful chance the Court of Appeal would do that. The submissions on one side effectively rest on points which I\u00a0carefully considered and on which I\u00a0formed a\u00a0very clear view. I\u00a0have discerned a\u00a0clear line between the Malabu corruption, which can be traced through, and a\u00a0principled basis for putting Mr.\u00a0Adoke the other side of that line. The submissions now made are a rerun of that on which I am satisfied there is no real prospect of success. The difference is the addition on top of extra effectively new submissions, which are entirely different to those advanced before me. For example, there is what appears to be a\u00a0similar fact-type argument based on matters which probably are not admissible and a\u00a0question as to the legal relevance of close associate status. Considering it very carefully even with these additions, and even stepping back and re-interrogating myself on it, I\u00a0remain of the view that this is a\u00a0question on which there is no real prospect of success. 9. In relation to Ground 2, gross negligence, again, I\u00a0consider there is no real prospect of success. In part there is an element of that which is dependent on the first limb because the gross negligence is one step down the chain. So if no real success on Ground 1, then no real prospect of success on Ground 2. But even if it stood alone, I\u00a0conclude that there is no real prospect of success. 10. Again there has been something of a\u00a0misstatement of my approach. I\u00a0did summarise some of the other authorities in order to highlight the need for there to be a\u00a0clear distinction maintained in one's mind between casual negligence and gross negligence and I used some of those authorities to point that distinction, but I\u00a0then went on to highlight that I was applying the test from The Hellespont Ardent and making my findings in terms of those tests. So it can be seen that I\u00a0very carefully applied the test from The Hellespont Ardent. So the argument again appears to be an attempt to go behind the way I\u00a0have put it, alternatively to rewrite The Hellespont Ardent test in a way which was not really argued before me. 11. So far as the factual side of it goes, it is submitted that I\u00a0made a finding of negligence and the argument jumps off from there. To be clear, the question of negligence per se was not an issue for me and I\u00a0did not have to decide it. What I\u00a0said was that the bank was \u201con notice of a\u00a0risk, possibly amounting to a\u00a0real possibility of the relevant fraud\u201d. That is not a\u00a0finding but an indication of roughly where in the scale the risk sat. 12. What that does illustrate is that on any basis, without completely reworking the factual analysis, you are at a\u00a0place which is a\u00a0country mile away from gross negligence, whatever the epithet one uses to describe gross negligence. It follows that even if this ground were to stand by itself, this prospect of success would be no more than fanciful. 13. Finally, the argument has not explicitly been put before me on the basis of some other compelling reason. I\u00a0can see it is possible, given the amount in issue and the status of the claimant as a\u00a0country, that that is a\u00a0point which might be argued. I\u00a0am not going to consider it, I\u00a0have not been asked to and I\u00a0very firmly am of the view that arguments about some other compelling reason are ones for the Court of Appeal, not for this court. That is the more so when I\u00a0have made clear the arguments which are sought to be raised are ones which ask the Court of Appeal to pick through detailed factual findings and would consequently on any analysis be asking the court to take a\u00a0good deal of its time effectively reworking the judge's factual homework. So you can obviously go and ask the Court of Appeal, Mr.\u00a0Masefield, but no. Judgment on Costs 14. I\u00a0now have to make a\u00a0decision on the basis on which costs are awarded. I\u00a0am going to give a\u00a0brief set of reasons which can be given a\u00a0little bit more amplification and context if anybody wants to take my decision any further. 15. The backdrop to this is that this is a\u00a0very serious issue of course in this case, given the size of the costs in issue. The question of basis can make an enormous difference. 16. The starting point for me here is I\u00a0am not looking at what one might call a\u00a0classic indemnity costs case. This is not a\u00a0case where outside the factor of the indemnity clause effectively one would be looking at a\u00a0submission in relation to indemnity costs. That is a\u00a0submission which Mr.\u00a0Masefield has made and I\u00a0completely accept that submission. 17. So the starting point has to be the indemnity clause. Even to the extent that I\u00a0conclude that the indemnity clause does bite, I\u00a0still retain a\u00a0discretion. The point between the parties is whether it applies between the parties to the agreement or only to third parties. The Federal Republic of Nigeria says that it does not. It says that even the second half of 10.1(b) is directed to third-party claims because of a\u00a0number of factors; in particular, the reference to negligence as opposed to gross negligence. 18. JP Morgan says this is a\u00a0different clause to 10.1(a) which Professor\u00a0Burrows said and the Court of Appeal says applies to third-party claims. It also says that if you "just read it", you can see that it does apply to a\u00a0situation such as this. 19. Cutting a\u00a0long story short and doing no justice at all to the detail of the argument, I\u00a0agree that 10.1 is, looked at overall, something which is primarily directed to third-party situations. But, having said that, there is nothing in the wording of (b) which confines it to third-party situations only. One looks at the relevant parts of 10.1(b) in the context of the lead-in to the main part of 10.1 — which covers costs, claims, losses, liabilities, damages and so forth imposed on, incurred by, and so forth — and then you go down into (b) with "or otherwise arising or under or in connection with" — "(including, without limitation, the costs of the Depository defending itself successfully against alleged fraud, negligence or wilful default)." 20. Those words are ones which one would expect to answer to this fact situation. Suppose, for example, the Federal Republic of Nigeria wrongly accused JPM of fraud. It would seem odd if that indemnity were not to answer with wording such as there is. The broad words of the clause, read in the ordinary and natural sense, in my judgment suggest that the clause is apt to cover. 21. The Federal Republic of Nigeria has said that would lead to a\u00a0complication because the court would then need to find if JPM had been negligent in order to see whether the exception were to bite and that that would be an odd fit. It seems to me that is reverse engineering the argument, which is not permissible. Further in my judgment, while there is a\u00a0carve-out needed for circumstances in which the clause does not bite, one can see it is intended to match against the allegations. So, in my judgment it would be designed to disapply if, for example, there was fraud established. It is designed to disapply if the negligence which is alleged is established. It is not designed to create a\u00a0system for double findings. Thus one reads it as matching the allegation. 22. So that is the starting point in my judgment; the indemnity clause is on its face apt to cover what has happened in this case. But that does not mean that as night follows day one goes into indemnity basis. While the court has said that the discretion should ordinarily be exercised to reflect the contractual right, it is conceded that I\u00a0have a\u00a0discretion as to exactly how to apply it. Briggs LJ in Littlestone did not specifically say that the indemnity basis should be applied, and he was dealing with specific words in that case. One must also bear in mind the need for a\u00a0degree of nuance, bearing in mind the other facts of the case, for example the kinds of facts I\u00a0am dealing with in this kind of costs argument today. 23. The next factor, Calderbank offers. The law is clear: it does not follow that because there has been a\u00a0Calderbank offer there will be liability on the indemnity basis. See Excelsior. The Calderbank offers here: I\u00a0can see that there are a\u00a0number of factors why JPM would say that there ought to be real weight given. However, I\u00a0am not minded to regard this as a\u00a0particularly heavy factor assisting JPM in the balance towards indemnity costs in a\u00a0situation where I\u00a0accept that that is highly complex litigation. I\u00a0do accept that the offers were low judged against, for example, what was in play in 2013. I\u00a0do of course note the point made by Ms.\u00a0Phelps, that certainly as at a\u00a0particular point in the time line there was a\u00a0decision in Italy in relation to the fraud; but at the same time, that continues to be an ongoing story. We are at a\u00a0particular point in the time line that there was much still to think about. I\u00a0also bear in mind that, as Mr.\u00a0Masefield pointed out, this is not a\u00a0Part 36 offer case, and if there were a\u00a0Part 36 offer, then even then it does not follow that one would order indemnity costs. So while I\u00a0do understand why weight is put on it by JPM and I\u00a0have given it careful thought, I\u00a0am not minded to put a\u00a0huge amount of weight on the failure to accept the offer. 24. The truth is that what one sees here sees here is thoroughly different views of the merits of the case which, on the analysis which I\u00a0have taken post-trial, I\u00a0consider to be wrong on the part of Federal Republic of Nigeria, possibly misguided; but I\u00a0say that post-trial, and there is a\u00a0danger of looking at it with the benefit of hindsight. 25. I\u00a0then turn to the question of issues-based costs order. There was a\u00a0slight difference between the parties on the law as to the need for unreasonableness. Mr.\u00a0Masefield took me to various portions of the White Book and so forth, pointing out that the need for unreasonableness in order to get an issues-based costs order was done away with by the CPR reforms. 26. However, having said that, he took me to a\u00a0passage in one of Lord\u00a0Woolf's judgments saying that the courts would be much more ready to make issues-based costs orders post the reforms. History has not entirely borne him out on that. In subsequent cases there are any number of dicta about the importance of maintaining at least in broad terms the overall principle that costs follow the event, albeit while trying to hold that line to which he alluded, of discouraging parties from a\u00a0"no stone unturned" approach to litigation. 27. Where the balance of authorities lies at the moment is that issues-based costs orders are not often made. They tend to be only made in cases where there is truly a\u00a0discrete issue, and the authorities from the Court of Appeal enjoin the poor unfortunate trial judge to consider first whether it is appropriate to make a\u00a0percentage-based reduction before launching into the complexities of an issues-based costs order. So far as issues-based costs orders are concerned, I\u00a0would also say that while I\u00a0do not accept the full extent of JP Morgan's argument about the need for unreasonableness, it is the case that, reflecting the authorities to which I\u00a0have just referred, it is an unusual case in the modern world where you end up with an issues-based costs order such that you do not simply knock off something for that issue but also award the costs of that issue to the overall unsuccessful party who has been successful on that issue. 28. All of that means that in this case I\u00a0am not going to make an issues-based costs order. This is a\u00a0case where the Nigerian law issues might be said to be more discrete than many, and there will be discrete elements that can be picked out — but they are still hideously entwined in the rest of the preparation. For example, how do you pull out the time referable to submissions, the time referable to preparation? We do not want to get into the line counting from the transcript and so on and so forth. Then there is the additional complication that the largest of the issues which might be tempting to regard as a\u00a0discrete issue is one where a\u00a0significant chunk of the costs has already been dealt with in relation to the summary judgment and the bank has already borne much of these costs. So there is danger of creating a\u00a0further subsidiary difficulty in splitting out costs. 29. The other issues: the other Nigerian law issue is one best seen as part of the claim. The other issues are in my view really issues which are exactly the sort of thing which are generally intended to be swallowed by costs following the event or a\u00a0very small percentage reduction. 30. So, putting all of those things together, the conclusion which I\u00a0reach is that JP Morgan should have its costs but they should be on a\u00a0standard basis. That reflects the fact that there is an indemnity clause which is giving JP Morgan some assistance, but it also gives something in the direction of Federal Republic of Nigeria, in particular in relation to the issues of Nigerian law. 31. It also gives scope for the court's discretion in a\u00a0case where it seems to me that there is a\u00a0danger, if one gives an indemnity costs order, of doing precisely the thing of encouraging parties in the "no stone unturned" approach to litigation. So in this case it seems to me the justice of the case and the various arguments are best reflected by giving JP Morgan costs on a\u00a0standard basis. 32. We are going to move on to a\u00a0question of payment on account. I\u00a0am just going to say now loud and clear that because I\u00a0have just said standard and because of the frankly enormous sums involved, I\u00a0am thinking small percentage, so the figure which is in my mind at the moment is somewhere well below 50%. I\u00a0just put that there as a\u00a0framework for the debate which will follow. Judgment on Payment on Account 33. Thank you very much. Bearing in mind the very large amount of money and the authorities, and I\u00a0do tend to follow the approach outlined by Leggatt LJ in Dana Gas so far as one is able. 34. The figure to which I\u00a0would come would be somewhere around 40%. I\u00a0am going to say 9 million, which I\u00a0think is fractionally over 40%. I\u00a0might have gone a\u00a0little lower, because I\u00a0do think it in these cases where there are very, very big sums as stake, the margin for a\u00a0bigger reduction on assessment is considerable. However, the hourly rates in this case do not appear to be too appalling, so I\u00a0have come up a\u00a0little from where I\u00a0would have been if they were higher. So 9 million. 35. On timing, 28 days. It is a\u00a0very large sum of money. Governments have procedures which they have to go through, but the payment ought to be made or not made before JPM have to put in their document in relation to appeal. — — — — — — — — — —<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

MR. JUSTICE COCKERILL : Judgment on Permission to Appeal 1. Thank you very much. Mr. Masefield, I am not going to give you permission to appeal. While I am grateful for the focus and clarity of your grounds, the fact that you have produced grounds (which is by no means always the case) and the courtesy with which the submissions…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[7665],"kji_chamber":[],"kji_year":[32183],"kji_subject":[7625],"kji_keyword":[7705,8052,10967,8358,17073],"kji_language":[7611],"class_list":["post-663110","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-high-court-commercial-court","kji_year-32183","kji_subject-commercial","kji_keyword-appeal","kji_keyword-costs","kji_keyword-indemnity","kji_keyword-judgment","kji_keyword-negligence","kji_language-anglais"],"yoast_head":"\nTHE FEDERAL REPUBLIC OF NIGERIA v JP MORGAN CHASE NA - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/ru\/jurisprudences\/the-federal-republic-of-nigeria-v-jp-morgan-chase-na\/\" \/>\n<meta property=\"og:locale\" content=\"ru_RU\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"THE FEDERAL REPUBLIC OF NIGERIA v JP MORGAN CHASE NA\" \/>\n<meta property=\"og:description\" content=\"MR. JUSTICE COCKERILL : Judgment on Permission to Appeal 1. Thank you very much. Mr. Masefield, I am not going to give you permission to appeal. 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JUSTICE COCKERILL : Judgment on Permission to Appeal 1. Thank you very much. Mr. Masefield, I am not going to give you permission to appeal. 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