On April 20, 2016, the Hague District Court in the Netherlands overturned [3] a fifty billion dollar award that Russia had been ordered to pay to shareholders of the now defunct oil company Yukos in a decision from July 2014. In the original case, Yukos brought a claim against the Russian government to the Permanent Court of Arbitration (PCA) under the Energy Charter Treaty [4] (ECT) alleging Russia was liable for expropriating the former Yukos shareholders’ investments through use of tax laws and criminal punishments without providing adequate compensation. The ECT is an international agreement intended to protect investors. The PCA held that Russia was bound by Article 45 of the ECT, which allows for provisional application of the treaty pending ratification, and awarded Yukos fifty billion dollars in damages to be paid by Russia, the largest arbitration award ever issued. However, the District Court disagreed, stating that Article 45 acted as a jurisdictional bar on the tribunal’s jurisdiction: “The Court finds that the wording of Article 45 necessitates an examination of whether or not the provision in each separate article of the ECT is contrary to the constitution or other legislation of the state involved.” The District Court’s examination of Russian legislation found that a legal provision is required for subjecting Russia to such disputes, which requires the approval of the Russian Parliament. Therefore, since Russia had signed but not ratified the Treaty, it was not bound by it. This decision can be appealed to higher Dutch courts.