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SGS v. Benin, Judgment of the Paris Court of Appeal, June 23, 2026

23 Jun 2026

Société Générale de Surveillance S.A (SGS) v. Republic of Benin, ICC Case No. 22581/DDA

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Judgment of the Paris Court of Appeal (French)

Document Details:

LISTED PARTICIPANTS

SGS v. Benin

Judgment of the Paris Court of Appeal (French)

Participants listed are for this document only and may not include all participants involved in the entire case. Always consult the original documents.

Claimant appointee

Respondent appointee

Tribunal/Panel chair

Arbitrator(s)

Sole Arbitrator

ICSID Annulment Committee president

ICSID Annulment Committee members

WTO Appellate Body members

WTO Appellate Body chair

Judges

M. Daniel Barlow, Jacques Le Vaillant, Joanna Ghorayeb

Claimant's counsel

Nicolas Schbath

Claimant's law firm

Respondent's counsel

Diane Houngue

Respondent's law firm

Other counsel

Claimant's expert

Claimant's expert firm

Respondent's expert

Respondent's expert firm

Claimant's witness

Respondent's witness

Other witnesses

Tribunal secretary

Tribunal assistant

Third-party funder

Entities

Benin

Country

France

Print reporter

Document Summary

SGS v. Benin

Judgment of the Paris Court of Appeal (French)

This summary note is machine-generated. Always consult the original materials.

Procedural Posture

This decision by the Paris Court of Appeal (International Commercial Chamber) addresses a request for the rectification of a material error (requête en rectification d'erreur matérielle) filed by the applicants concerning a prior judgment rendered by the Court on January 11, 2022, in a dispute against the State of Benin.

Parties' Positions and Legal Issues

The applicants contended that the Court committed a material error in its January 2022 judgment regarding the starting date for the application of the Beninese legal interest rate. They argued that the Court failed to draw the proper consequences from prior decisions of the Beninese courts, asserting that the interest should accrue from November 16, 1994, rather than May 12, 1999.

Court's Analysis and Findings

The Court analyzed the application under Article 462 of the French Code of Civil Procedure, which permits the correction of material errors or omissions but strictly prohibits any modification of the substantive rights and obligations recognized by the underlying decision. The Court observed that in the January 2022 judgment, it had specifically adjudicated the starting date of the interest, expressly fixing it at May 12, 1999, corresponding to the date the disputed claim was judicially recognized in the first instance.

Consequently, the Court determined that the applicants were not seeking the correction of a mere clerical or material error. Instead, under the guise of a rectification request, they were impermissibly attempting to substantively revise the Court's prior legal determination, thereby challenging the authority of res judicata.