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A $250 Million Judgment Debt, Frozen Worldwide

Oct 25
1 min read

The October 2026 decision

In FitzWalter Capital Aviation Services LLC v VietJet Aviation Joint Stock Company, [2026] EWHC 2633 (Comm), the English Commercial Court addressed enforcement of a judgment debt described as approximately $250 million. The judgment records that approximately $2 million had been paid and that the balance remained outstanding.

The court granted a worldwide freezing order after concluding that there was solid evidence of a real risk of dissipation. The judgment discusses VietJet's order book and pre-delivery-payment rights as potential sources of value relevant to enforcement.

What a freezing order does—and does not do

A freezing order is an asset-preservation measure. It is not a criminal finding and does not itself transfer ownership of assets to a creditor. Its purpose is to restrain dealings that could frustrate enforcement, subject to the terms, exceptions, and disclosure requirements in the order.

Practical lessons for judgment creditors

• Map assets, contractual rights, and jurisdictions before deciding where to seek relief.

• Build a record directed to the governing test for dissipation risk; a large unpaid judgment alone may not be enough.

• Plan for recognition, disclosure, and enforcement in each relevant jurisdiction.

• Treat litigation milestones separately from actual cash recovery.

Primary source

This article is for general informational purposes only. It is not legal, tax, accounting, or investment advice, does not create an attorney-client relationship, and should not be relied on for any specific matter. Laws, court orders, deadlines, and procedural rules can change and may vary by jurisdiction. Consult qualified counsel and other professional advisers about the facts of your matter.

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