Malaysia Delivers Knockout Blow To USD15 Billion Sulu Fraud

Malaysia has achieved a decisive legal victory in the Sulu claimants case, with the Paris Court of Appeal completely annulling a controversial USD14.92 billion arbitration award and ordering the claimants to pay 200,000 euros in costs.

Malay Mail

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Malaysia has scored a decisive legal victory in its long-running dispute with the so-called Sulu claimants, after a Paris court on Tuesday (9 December) threw out a controversial USD14.92 billion (approximately RM61.28 billion) arbitration award and ordered the claimants to pay 200,000 euros (approximately RM959,560) in legal costs.

The case stems from eight individuals claiming to be descendants of the defunct Sultan of Sulu, Sultan Jamalul Kiram II, who received the purported award against Malaysia in February 2022.

Malaysia views this as “a sophisticated abuse of the arbitral process and international law” – essentially an attempt to hold a sovereign state to ransom.

The Sulu claim to Sabah originates from an 1878 agreement made between Sultan Mohammed Jamalul Alam of Sulu and European colonists, which the current claimants interpret as a lease for the territory and assert their inherited rights through lineage to Sultan Jamalul Kiram II, the last Sultan who died in 1936.

In 2013, a group from Sulu entered Lahad Datu to assert their claim to Sabah, which led to a standoff with Malaysian security forces and prompted Malaysia to stop payments to the Sulu Sultanate, further escalating the territorial dispute.

Malaysia has consistently rejected these claims as baseless and fraudulent.

A Pattern Of Victories Across Europe

The French court’s ruling was straightforward: Spanish arbitrator Gonzalo Stampa lacked jurisdiction to render the award because there was no valid arbitration agreement binding Malaysia, making the entire arbitration process invalid from the start.

However, this isn’t Malaysia’s first victory in its multi-front legal battle before European courts.

France:

June 2023: Paris Court of Appeal refused to recognise Stampa’s earlier “Partial Award” from 2020
November 2023: Paris courts oversaw the withdrawal of measures against Malaysian diplomatic buildings in France
November 2024: France’s Supreme Court dismissed the Sulu claimants’ challenge
December 2024: Complete annulment of the Final Award

Spain:

December 2023: Madrid Criminal Court found Stampa guilty of contempt of court, sentencing him to six months in prison and a one-year ban from practising as an arbitrator for disobeying orders of the Madrid High Court of Justice
February 2025: Madrid High Court of Justice dismissed the claimants’ application challenging earlier rulings against Stampa

Netherlands:

June 2023: Hague Court of Appeal also delivered a victory for Malaysia

Government Celebrates Win

Law Minister Datuk Seri Azalina Othman Said, who heads Malaysia’s special task force handling the case, expressed gratitude to Prime Minister Datuk Seri Anwar Ibrahim and various government agencies for their coordinated effort.

This victory is not just a legal success, but a victory for the dignity, sovereignty and rights of all Malaysians, especially the people of Sabah.

The government hopes this decision will “put an end to all the baseless attempts from the so-called Sulu claimants to extort money and assets from the people of Malaysia.”

While this represents a significant victory for Malaysia, the government also made clear it’s prepared to continue fighting if the claimants pursue the matter in other courts.

The Sulu claimants have been backed by Therium, a litigation funder that finances legal cases in exchange for a share of any winnings.

For now, though, Malaysia can celebrate a significant legal win that protects both its sovereignty and its citizens from what it calls a fraudulent claim that “tarnishes the reputation of the globally respected arbitration system.”

Alhamdulillah, dengan izin Allah SWT, Malaysia mencatat kemenangan besar apabila Mahkamah Rayuan Paris pada 9 Disember 2025 membatalkan sepenuhnya “Final Award” dalam tuntutan pihak yang mendakwa sebagai waris Kesultanan Sulu terhadap Sabah.

Kemenangan ini bukan sahaja kejayaan… pic.twitter.com/XnVe42y3Gm
— Azalina Othman Said (@AzalinaOthmanS) December 10, 2025