The Paris Court of Appeals set aside an investment arbitration award for “manifest, effective and concrete” violation of the international public order. It ruled that the award had provided the respondent with a title for an investment made in Laos by fraudulently obtaining an administrative authorization for exploitation of natural resources.

The two original versions of the contract in English and in Laotian contained different wordings of an article: the former subjected the execution of the contract to a funding obligation and the other did not. The latter was the one used to request the authorization from the Government to exploit the natural gold resources from the country. The Court rejected the fraud allegations finding that both versions were drafted differently at the outset. However, it did rule that such dilatory acts demonstrated how substantial the condition was for the Laotian Authorities.