December 19, 2025 – The long-running legal dispute surrounding Russian fertiliser producer TogliattiAzot (ToAZ) has reached a significant turning point following a judgment delivered by the Irish Court of Appeal on 19 December 2025. The decision, issued in Trafalgar Developments Limited & Others v Mazepin & Others ([2025] IECA 280), overturns an earlier High Court ruling concerning Ireland’s jurisdiction over certain defendants involved in the international ownership dispute.
The proceedings were brought by four offshore companies; Bairiki Incorporated, Kamara Limited, Instantania Holdings Limited and Trafalgar Developments Limited (collectively the “BKITs”), which allege that Russian businessman Dmitry Mazepin, chemical producer Uralchem and associated parties participated in a coordinated scheme to deprive them of their interests in ToAz.
The scheme involved the misuse of Russian legal proceedings and corporate raiding tactics intended to undermine the claimants’ shareholdings.
The appeal concerned whether Irish courts could properly exercise jurisdiction over certain Russian defendants and Uralchem Holding Plc, a Cypriot company. The claimants had relied partly on the involvement of Eurotoaz Limited, an Irish-registered company, to establish a connection with Ireland.
The December 2025 judgment represents a reversal of the earlier jurisdictional position established by the Irish High Court in March 2022. At that time, the High Court ruled that proceedings against certain defendants, including Dmitry Mazepin and Uralchem, could continue in Ireland. This earlier decision was reported in our article, Irish Court Confirms Jurisdiction in Case Against UCCU, Mazepin and Eurotoaz. However, the Court of Appeal’s subsequent ruling overturned the relevant jurisdictional findings, significantly altering the procedural position of the ongoing litigation.
The Court of Appeal concluded that Russia, rather than Ireland, was the natural forum for hearing the claims against the relevant Russian defendants. It also determined that the requirements for establishing jurisdiction over Uralchem Holding under Article 8(1) of the Recast Brussels Regulation had not been satisfied.
Accordingly, the Court allowed the appeal and ordered that service of the proceedings on those defendants be set aside.
Implications for the TogliattiAzot Dispute
The judgment represents an important procedural setback for the claimants, potentially limiting their ability to pursue certain defendants through the existing Irish litigation.
However, the decision does not establish whether the alleged conspiracy occurred or determine the lawfulness of the defendants’ conduct. Instead, it addresses the jurisdictional question of which courts may properly hear the dispute.
The ruling also demonstrates the difficulties associated with pursuing international commercial disputes where the alleged wrongdoing, relevant evidence and principal parties are located primarily outside the jurisdiction in which proceedings are brought.
For the former shareholders and other entities connected with ToAz, the decision may require a reassessment of litigation strategies, including the possibility of pursuing remedies in other jurisdictions.
Although the December 2025 ruling significantly changes the procedural landscape of the Irish proceedings, it does not resolve the wider ownership dispute or determine the substantive claims advanced by the parties.
Read the full court judgment here: Irish Court of Appeal, Trafalgar Developments Limited & Others v Mazepin & Others, [2025] IECA 280, 19 December 2025.
