Minister Azalina Othman Said, who has led the Malaysian response to the Sulu arbitration, has announced December 7th as the date when the final ruling will be published. Image Source: Bernama (left), GlobalArbitrationNews (Right)

Malaysian Minister in the Prime Minister’s Department for Law and Institutional Reform, Datuk Seri Azalina Othman Said, confirmed the date in a statement following a key hearing on 7 July. During that session, the court concluded its examination of the legal arguments for and against the annulment.

Azalina also disclosed that the claimants had attempted to delay the proceedings, requesting more time to address a written opinion from the French Public Prosecutor. However, the court rejected the postponement bid in the latest setback for the purported Sulu heirs, choosing instead to proceed to deliberation.

The court rejected a bid to postpone the hearing in the latest setback for the claimants.

Azalina has stated she is confident the court would side with Malaysia—a view reinforced by the consecutive legal defeats for the claimants in Spain, France, the Netherlands and Luxembourg.

Although French courts have previously ruled that former arbitrator Gonzalo Stampa lacked jurisdiction to hear the case, the award he issued in 2022 technically remains in force. Under French law, a ruling on jurisdiction and attempts to enforce awards is treated separately from a ruling on the validity of the final award itself.

Although French courts have previously ruled that Spanish arbitrator Gonzalo Stampa lacked jurisdiction to hear the case, the award he issued in 2022 technically remains in force.

Therefore, despite France recognizing the revocation of Stampa’s role as arbitrator, and the blocking of the claimants’ attempts to seize Malaysia’s assets to pay the award, the multi-billion-dollar arbitration award itself remains unresolved—a gap the 7 July hearing aimed to close.

While five months may seem a long time for a decision, such delays are not uncommon in complex international arbitration cases. During this time, the court will review evidence and draft its final decision.

Should the court ultimately rule against Malaysia, the country could face renewed efforts to enforce the $14.9 billion award in foreign jurisdictions in what would likely be a costly legal back-and-forth given the attitude of European courts to earlier attempts at enforcement. Whether the Sulu claimants and their backers would be willing to continue to fund such ventures is unclear.

Conversely, a favorable ruling could decisively end one of the most controversial international legal disputes involving sovereign rights, colonial-era agreements, and unregulated litigation funding.

REFERENCES

Bernama. (2025, July 18). Paris Court to rule on Sulu claim annulment on Dec 9. Bernama. Retrieved July 21, 2025, from https://www.bernama.com/

KnowSulu. (2025, July 1). How did we get here? A timeline of the Sabah dispute. KnowSulu. Retrieved July 21, 2025, from https://knowsulu.ph/