What Malaysia is fighting for?
In February 2022, eight individuals who claimed to be the descendants of the defunct Sultan of Sulu, Sultan Jamalul Kiram II, received a purported final award worth $14.92 billion in an arbitration proceeding against the Government of Malaysia. The said award was delivered by the Spanish arbitrator, Dr Gonzalo Stampa.
The Sulu case is a sophisticated abuse of the arbitral process and international law. It is an attempt to hold a sovereign State to ransom, and the continued existence of the award tarnishes the reputation of the globally respected arbitration system.
Malaysia is pursuing legal proceedings across jurisdictions to defeat the Claimants’ unlawful enforcement campaign. On 9 December 2025, the Paris Court of Appeal, sitting at the seat of the arbitration, fully annulled the purported Final Award, confirming that the arbitrator lacked jurisdiction and that no valid arbitration agreement bound Malaysia.
In November 2023, the Paris Courts oversaw the withdrawal of the measures registered by the Claimants on the diplomatic buildings owned by Malaysia in France. The Paris enforcement judge quashes its prior ex parte order that authorized a statutory mortgage to be registered on these diplomatic buildings. The judge also recorded the Claimants’ withdrawal from the proceedings they had initiated to seize these diplomatic buildings.
On 22 December 2023, the Spanish Criminal Court found Dr. Stampa guilty of contempt of court. The Criminal Court has sentenced Dr. Stampa to six months in prison and a year ban from professional practice as an arbitrator.
In November 2024, the French Supreme Court for civil and criminal matters, the Court of Cassation, fully dismissed the challenge filed by the so-called heirs. The decision means that the Partial Award, which was the initial basis for the sham Final Award, is not recognised under French law.
“On 9 December 2025, the Paris Court of Appeal fully annulled the purported Final Award. The Sulu Special Secretariat War Room stated that the Court also ordered the Claimants to pay €200,000 in legal costs.
With these consecutive victories, Malaysia is advancing steadily towards the complete annulment of the purported Final Award in France.”