Enforcement of arbitration awards: state immunity

A short but important procedural point arose before the Court of Appeal in General Dynamics United Kingdom Ltd v State of Libya [2019] EWCA Civ 1110. Where an enforcement order was obtained in England in respect of a state, was there any requirement for either the arbitration claim form or the order itself to be served on the state or could the court dispense with service?

The point was of major significance in the present case. Libya was in turmoil in that it had no fully functioning government and service on the state created severe practical difficulties. This was, therefore, a test case on service of enforcement proceedings on a dysfunctional foreign government.