Mikhail Fridman v Agrofirma Oniks LLC & Anor

Mikhail Fridman v Agrofirma Oniks LLC & Anor

The court held that the common law principle requiring presence within the jurisdiction for service is a substantive jurisdictional requirement rooted in international law and territoriality. Mr Fridman's enforced and indefinite exclusion from the UK meant he was not present for jurisdictional purposes, and service...

Source-derived case information.

Parties
Appellant: Mikhail Fridman; Respondent: Agrofirma Oniks LLC; Respondent: Agro UG V LLC
Jurisdiction
England and Wales
Judgment Date
19 February 2026
Procedural Posture
Civil Appeal / Court of Appeal Judgment
Outcome
Appeal allowed
Legal Topics
Service of Process, Jurisdiction, Sanctions, Territoriality, CPR Rule 6.9
Civil Procedure Private International Law Service of Process Jurisdiction Sanctions Territoriality CPR Rule 6.9

Source-derived case record

Summary, issues, holding and outcome

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Parties

Mikhail Fridman

Appellant

Agrofirma Oniks LLC

Respondent

Agro UG V LLC

Respondent

Procedural Posture

Civil Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether service of claim form at Athlone House was valid given Mr Fridman's exclusion from the UK
  2. 2 Whether presence within the jurisdiction is a substantive requirement for personal jurisdiction under English law

Ratio Decidendi

The court held that the common law principle requiring presence within the jurisdiction for service is a substantive jurisdictional requirement rooted in international law and territoriality. Mr Fridman's enforced and indefinite exclusion from the UK meant he was not present for jurisdictional purposes, and service at Athlone House was invalid.

Court Disposition

Appeal allowed

Orders

  • Order of the High Court set aside
  • Claimants must seek permission to serve outside the jurisdiction if they wish to proceed