Procedural Posture

This document constitutes the Statement of Case submitted by Process and Industrial Developments Limited (Claimant) in an arbitration against the Ministry of Petroleum Resources of the Federal Republic of Nigeria (Respondent). The arbitral proceedings are governed by the Nigerian Arbitration and Conciliation Act (Cap A18 LFN 2004), with the seat of arbitration designated as London, England. The pleading formally sets out the Claimant's factual allegations, legal claims, and quantum of damages sought following the termination of a commercial contract.

Factual Background and Allegations

The dispute arises from a Gas Supply and Processing Agreement (the "Definitive Agreement") executed on 11 January 2010. Under the contractual framework, the Respondent was obligated to supply 400 MMSCuFD of Wet Gas (Associated Gas) to the Claimant's proposed gas processing facility in Calabar, Nigeria, at no cost. In exchange, the Claimant was to construct and operate the facility, strip the Natural Gas Liquids (NGLs) for its own commercial benefit, and return Lean Gas to the Respondent for domestic power generation.

The Claimant alleges that the Respondent comprehensively failed to meet its supply obligations. Specifically, the Claimant asserts that the Respondent failed to secure the necessary gas supplies from the international oil companies operating the relevant offshore oil mining leases (OMLs 123 and 67). Furthermore, the Claimant contends that the Respondent failed to complete the requisite pipeline infrastructure, notably the Adanga Pipeline, which was essential for delivering the Wet Gas to the processing site.

Legal Claims and Repudiation

The Claimant asserts that the Respondent's failure to perform its fundamental obligations under Phase 1 and Phase 2 of the Definitive Agreement constitutes a repudiatory breach of contract. Following unsuccessful attempts to resolve the impasse and secure alternative gas sources, the Claimant formally accepted the Respondent's repudiation and terminated the Definitive Agreement on 20 March 2013. The Claimant argues that the Respondent's conduct evidenced a clear unwillingness or inability to perform its contractual duties.

Prayer for Relief

In its prayer for relief, the Claimant seeks substantial damages in the quantum of US$5,960,226,233. This figure represents the Claimant's calculated loss of profits that it would have realized from the sale of the extracted NGLs over the 20-year lifespan of the project. Additionally, the Claimant requests pre-award and post-award interest at a rate to be determined by the Tribunal, alongside any further relief deemed appropriate.