How does the French ruling conflict with the 2020 Malaysian court decision?

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The French Ruling Directly Contradicts a 2020 Malaysian High Court Decision Regarding the Sulu Sultanate Claim

A French arbitration court has ordered Malaysia to pay up to US$14.9 billion to the descendants of the defunct Sulu sultanate, based on an alleged violation of a 1878 land lease agreement. This ruling stands in direct opposition to a 2020 decision made in the High Court of Kota Kinabalu, which favoured the Malaysian government. The French arbitration, presided over by Spanish arbitrator Gonzalo Stampa, deemed the 1878 treaty an "international private lease agreement" of a commercial nature and found Malaysia in breach by ceasing the annual RM5,300 cession payments since the 2013 Lahad Datu incursion.
The Malaysian High Court Ruling Favoured the Government

In 2020, the Malaysian High Court in Kota Kinabalu, in a case identified as the Malaysian government versus Nurhima Kiram Fornan & Ors, ruled in favour of the Malaysian government. This legal action was initiated by the federal government to prevent the claimants from proceeding with arbitration. Crucially, the High Court determined that there was no binding agreement between Malaysia and the heirs of the Sultan of Sulu that mandated arbitration for dispute resolution. The Malaysian government had sought a declaration affirming the absence of an arbitration agreement and asserting Malaysia as the appropriate forum for resolving disputes arising from the deed of cession.
The French Arbitration Asserted a Commercial Lease Agreement

Conversely, the French arbitration court, through arbitrator Gonzalo Stampa, characterized the 1878 treaty as an "international private lease agreement" with a commercial nature. Based on this interpretation, the court found Malaysia's cessation of cession money payments since 2013 to be a breach of the agreement. The French ruling stipulated a three-month period for Malaysia to make the payment, failing which interest would be charged on the awarded sum.
Divergent Legal Interpretations of the 1878 Deed of Cession

The core of the conflict lies in the differing legal interpretations of the 1878 agreement and the enforceability of arbitration clauses. While the Malaysian High Court found no obligation to arbitrate, the French arbitration court upheld the treaty as a commercial lease agreement, thereby asserting its jurisdiction and finding a breach in Malaysia's actions. This divergence raises questions regarding which ruling will hold sway in international legal enforcement.

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How does the French ruling conflict with the 2020 Malaysian court decision?

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