But the question is that the decision of the Stockholm arbitration is final and must be executed. Moreover, the parties, Naftogaz and Gazprom, in the contract clearly indicated that the Stockholm arbitration is an instance to which they apply and which decision they recognize. Therefore, one way or another, Gazprom will have to admit this decision and implement it.

Another thing is that the Russian side has sought to find some kind of clutches (which, of course, can always be found) and tries to repeat the case with The Hague on the case of Yukos. But these things are absolutely unequal, because everything in Yukos was much more complicated. Then in the Hague, the court made a decision in favor of the shareholders of Yukos, and the Russian side is still able to postpone the execution of this decision, even for a short time, for several years.

However, attempts by the Russian side to cancel the decision of the Stockholm arbitration in the case of Naftogaz against Gazprom will not succeed for one simple reason: although the Stockholm arbitration uses Swedish law, this does not mean that the Swaia County Court of Appeal has some higher jurisdiction than international arbitration in Stockholm

Therefore, it can only lead to a few months delay with the execution of Gazprom's court decision, but it is unlikely that it will lead to its cancellation. The Sway County Court cannot cancel this decision - it can only be canceled by the Stockholm Arbitration, which accepted it. This is Gazprom's predicted tactic, to which it threatened to resort immediately after the sentence was passed.