what should have been paid. Once the dispute was underway, KRG stopped making any payments. This put one of the Claimants, Dana, in the position of facing insolvency, with the result that it would be unable to take the benefit of a favourable result in the arbitration, and it was feared that KRG might use Dana’s potential insolvency to terminate the agreement. To maintain the status quo while the proceedings continued, Pearl applied for an order pursuant to Article 25 of the 1998 LCIA Rules that KRG resume making payments. In July 2014, the Tribunal granted the order, but it became immediately apparent that KRG would not make the required payments. Consequently, Pearl made an application to the Tribunal for a peremptory order under section 41 of the Act, which was opposed by KRG. In October 2014, the Tribunal made an order that KRG should make a payment to Pearl of US$100 million within 30 days. If the sum remained unpaid after 30 days, the Tribunal would make a peremptory order to the same effect. In making its ruling, the Tribunal noted that KRG’s counsel had indicated that the reason for refusing to make the payments required by its previous order was the “bitter disputes” with Pearl. KRG did not make payment, so the peremptory order took effect. Subsequently, Pearl obtained the Tribunal’s permission under section 42(2)(b) of the Act to apply to the court to enforce the peremptory order. ISSUES BEFORE THE COURT Pearl applied for an order under section 42 of the Act, which allows the English High Court to make an order requiring a party to comply with a peremptory order made by a tribunal in an arbitration seated in England and Wales or Northern Ireland. 55