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On 20th December 2021 the Supreme Court handed down an important judgment on head of state recognition and foreign act of state in the ongoing battle for control over Venezuelan gold reserves worth nearly $2 billion and held at the Bank of England.

Teare J had ruled in favour of the Guaidó Board and the Maduro Board had then appealed successfully to the Court of Appeal. The Supreme Court allowed in part the Guaidó Board’s appeal from the Court of Appeal and dismissed the cross-appeal of the Maduro Board. The case was remitted to the Commercial Court for further consideration.

A copy of the Supreme Court’s judgment is here and the Registry’s summary is here.


The Guaidó Board was represented by Timothy Otty QC, instructed by Arnold & Porter LLP.

The Maduro Board was represented by Sir Jeffrey Jowell QC and Naina Patel, instructed by Zaiwalla & Co.

The Secretary of State for the FCDO was represented by Sir James Eadie QC and Jason Pobjoy, instructed by the Government Legal Department.

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