Crying Over Spilled Oil: The Brussels I Regulation and the Judicial Enforcement of Arbitral Awards

After the European Court of Justice ("ECJ") has considered the scope of the "Brussels Regime" vis-a-vis arbitral proceedings in some of its landmark decisions such as West Tankers or Gazprom, the recent London Steam-Ship Owners' Mutual Insurance Association (C-700/20) judgment, in which the ECJ ruled on the interpretation of the notion of "irreconcilable judgments" within the meaning of Article 34 of the Brussels I Regulation, adds yet another piece to this already tricky puzzle. In this article, I am critically assessing the conclusions of the ECJ in the London Steam- Ship Owners' ruling and discussing the implications of that decision for the future cohabitation of judicial and arbitral proceedings in the European Union.