Vol 23 (2026) - Issue 1

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Beograd Innovation Ltd v Somovidis [2025] EWHC 1182 (Comm)

Synopsis
The claimant, Beograd Innovation Ltd ('Beograd'), was the assignee of a Russian judgment debt claim against the defendant, Mr. Somovidis. Beograd sought recognition from the English courts of the Russian judgment, so that two immovable properties located in England which Beograd alleged to be ultimately owned by Mr Somovidis could be sold to satisfy the Russian judgment debt. Mr Somovidis was in a Russian bankruptcy proceeding, but he had ceased to be domiciled in Russia when the Russian bankruptcy proceeding commenced as he had relocated to the United Kingdom.
Mr Somovidis sought a permanent stay of Beograd's application for recognition of the Russian judgment on the ground that Russian law precludes creditors from bringing claims outside of the Russian bankruptcy process and so the English courts should cooperate and grant the permanent stay under the principle of modified universalism.
The High Court applied Kireeva v. Bedzhamov [2024] UKSC 39 and ruled that the principle of modified universalism had no application in this case because the common law immovables rule meant that English law does not recognise the immovable properties as falling within the scope of assets that are affected by the Russian bankruptcy. The English courts therefore do not have power to assist foreign office-holders by vesting in them immovable properties situated in England.
On this basis, the High Court declined to grant Mr Somovidis a permanent stay. The effect is that Beograd can now seek to enforce the Russian judgment debt before the English courts and seek execution against Mr Somovidis' immovable properties in England, despite there being an ongoing bankruptcy process in Russia.