Paris Appellate Court Annuls “Final Award”

The Paris Court of Appeal has, on 9 December 2025, annulled the award of about US$15 billion sought by the so-called heirs of Sulu against Malaysia, marking a final and decisive end in the longstanding dispute over territorial claims over Sabah. The court said that the arbitrator, Gonzalo Stampa, lacked jurisdiction and that there was no valid arbitration agreement binding Malaysia. The also ordered the Sulu claimants to pay €200,000 (RM960,000) in costs to Malaysia.

Chief Minister Datuk Seri Panglima Haji Hajiji Haji Noor said the decision is a victory for Sabah and Malaysia, saying, "I have stated previously, we will defend Sabah's sovereignty within the Federation of Malaysia, and we will never entertain such claims. The decision of the court once again vindicated Sabah's stand." Hajiji has said in 2023 that the so-called Sabah claim has no merit whatsoever and that the people of Sabah have always rejected any external claims on their homeland.

Eight Philippine nationals who claimed to be heirs of the now-defunct Sulu Sultanate had initiated arbitration proceedings in Spain, seeking billions in compensation from Malaysia over Sabah. Spain’s court-appointed arbitrator, Gonzalo Stampa, who acted on behalf of the Sulu claimants, had purportedly allowed “partial award” in May 2020.

In June 2021, the same Spanish court annulled Stampa’s appointment as an arbitrator which prompted Stampa to move the arbitration proceedings to Paris in February 2022 where Stampa purported won the arbitration proceeding against the Malaysian Government. In June 2023, the Paris Court of Appeal in France upheld Malaysia’s challenge against the decision. The Paris Court refused recognition and enforcement of Gonzalo Stampa’s "Partial Award" issued in 2020. In November 2024, the French Supreme Court dismissed the challenge filed by the claimants against the decision of the Paris Court of Appeal.

The powerful and well-known Sabah Law Society (SLS) said that the Paris Court decision to annul the "final award" is a clarification of legal position and safeguards Sabah's territorial integrity and that Sabah's status within the Federation is anchored in the Federal Constitution and the constitutional arrangements flowing from the Malaysia Agreement 1963. SLS said that Federal Constitution and the MA63 cannot be altered, challenged, or subjected to extraterritorial arbitral processes that lack lawful foundation.