Supreme Court Decides CC/Devas (Mauritius) Ltd. v. Antrix Corp.

On June 5, 2025, the Supreme Court of the United States issued a decision in CC/Devas (Mauritius) Ltd., et al. v. Antrix Corp., et al., No. 23-1201, holding that the requirements for a court to exercise personal jurisdiction over a foreign state under the Foreign Sovereign Immunities Act of 1976 (FSIA), 28 U.S.C. §§ 1330, 1602 et seq., are limited to those outlined in the FSIA itself and do not include a traditional minimum-contacts analysis.

Antrix Corporation, an entity owned and controlled by the Republic of India, entered into a satellite-leasing agreement with Devas Multimedia Private Ltd. The agreement provided that Antrix would manufacture and launch a satellite network into space, and Devas would lease part of the satellite capacity to provide broadcasting services in India.

The Indian government ultimately determined that the project’s satellite capacity would be insufficient and terminated the agreement under its force majeure clause. Devas then commenced arbitration against Antrix.

The arbitration panel found for Devas and awarded damages and interest. Devas confirmed the arbitration award in the United Kingdom and France, then sought to confirm the award in the United States, pursuant to the FSIA’s “arbitration exception,” which grants federal courts jurisdiction over foreign states seeking to confirm arbitration awards entered pursuant to international agreements or treaties to which the United States is a party. 28 U.S.C. § 1605(a)(6).

The district court confirmed the award and entered a judgment against Antrix. The Ninth Circuit reversed, holding that notwithstanding the FSIA’s jurisdictional requirements, Devas failed to establish the traditional “minimum contacts” requirements for personal jurisdiction.

The Supreme Court reversed. The Court held that FSIA’s “neighboring personal jurisdiction” provision grants personal jurisdiction over a foreign state any time (1) an immunity exception applies; and (2) the foreign defendant is properly served. 28 U.S.C. § 1330(b).

The Court explained that the FSIA provides a “comprehensive” statutory scheme regarding lawsuits of foreign states in American courts, and that the FSIA does not mention a traditional minimum-contacts analysis.

Justice Alito delivered the opinion on behalf of a unanimous Court.