The Supreme Court’s decision in The Law Debenture Trust Corp Plc v Ukraine 1 addresses issues relating to the capacity of foreign states, the contractual authority of ministers, duress, foreign act of state, and whether the international law doctrine of countermeasures can be integrated into domestic contractual rules. The case is likely to be remembered for establishing that a state can, in principle, rely on defences of duress of the person or duress of goods where threats have been made to its population or its territory. This is an important, and new, proposition. As will be further explained below, the case also includes