ICC Tribunal’s injunction against Patel Engineering creates more problems than it solves

On 25 November 2022, the ICC Tribunal majority in Republic of Mozambique v. Patel Engineering issued a controversial injunction against Patel Engineering, restraining it from “pursuing the determination of any matters in dispute between the Parties arising out of [their contract] in any other forum, even if only accessorily for the purpose of the adjudication of Treaty Claims, until this Arbitral Tribunal has taken its decision on those matters.”