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PCA Case No. 2025-17

IN THE MATTER OF AN ARBITRATION UNDER THE AGREEMENT BETWEEN THE REPUBLIC OF ARCADIA AND THE REPUBLIC OF VALDORIA FOR THE PROMOTION AND RECIPROCAL PROTECTION OF INVESTMENTS AND THE UNCITRAL ARBITRATION RULES (2013)

MERIDIAN HOLDINGS LTD.
Claimant

v.

THE REPUBLIC OF VALDORIA
Respondent

STATEMENT OF CLAIM

8 October 2026

I. Introduction

This Statement of Claim is submitted on behalf of Meridian Holdings Ltd. (“Meridian” or the “Claimant”) pursuant to Procedural Order No. 1 of 14 July 2026.

The dispute arises from the Concession Agreement of 12 May 2009, under which Meridian built and operated the Sunridge offshore platform in Valdorian waters.

After ten years of uneventful operation, Valdoria approved an expansion of the platform, watched it being built, and then terminated the Concession — relying on a decree that predates the approval by three years.

Meridian claims compensation of USD 184 million for the expropriation of its investment and for the breach of the fair and equitable treatment standard.

II. The Parties

Meridian is a company incorporated under the laws of the Republic of Arcadia, with its seat in Port Albany. It has held the Sunridge concession since 2009.

The Respondent, the Republic of Valdoria (“Valdoria”), acts in this arbitration through its Ministry of Justice. The Ministry of Energy is the authority responsible for the Concession.

III. The Facts

A. The Concession

Under Article 4 of the Concession Agreement, Meridian obtained the exclusive right to extract and process gas from the Sunridge field for thirty years.

Article 18 allows the Ministry to terminate the Concession only for a material breach that Meridian has failed to cure within ninety days of a written notice.

B. The approval of the works

In early 2019 Meridian applied to expand the platform by a second processing unit. The Ministry of Energy approved the works in writing on 12 May 2019.[cite]

During the site visit of 11 August 2019, officials of the Ministry inspected the construction and raised no objection; Ms Varga, who led the visit for Meridian, confirms this.[cite]

The second unit went into operation in March 2020 and has since processed gas without incident.

C. The termination

On 18 October 2021 the Ministry issued an inspection report alleging, for the first time, that the second unit lacked a permit under Decree No. 117.

Only fifteen days later, on 2 November 2021, the Ministry terminated the Concession with immediate effect, without any notice to cure.[cite]

Meridian protested and, on 20 January 2022, notified the dispute under Article 9 of the Treaty.[cite]

IV. Jurisdiction

Meridian is a national of Arcadia, and the Concession is an investment within the meaning of Article 1 of the Agreement between the Republic of Arcadia and the Republic of Valdoria (the “Treaty”).

The six-month negotiation period of Article 9(2) of the Treaty expired without a settlement on 20 July 2022.

V. Liability

A. Expropriation

A termination that deprives the investor of the whole value of its investment, without a legitimate public purpose and without compensation, is an expropriation. Tribunals have consistently so held, and the commentary agrees.[cite]

Valdoria cannot rely on Decree No. 117. Having approved the works and inspected them, the Ministry is bound by its own conduct.

B. Fair and equitable treatment

By approving the works and then terminating the Concession for those very works, Valdoria frustrated Meridian’s legitimate expectations and acted arbitrarily, in breach of Article 3 of the Treaty.

VI. Quantum

Meridian’s losses amount to USD 184 million, as Dr Brandt confirms on the basis of the discounted cash flows of the Sunridge platform.[cite]

VII. Relief Sought

Meridian respectfully requests the Tribunal to:

(a) declare that Valdoria has breached Articles 3 and 5 of the Treaty;

(b) order Valdoria to pay Meridian USD 184 million, plus interest at a commercial rate; and

(c) order Valdoria to bear the costs of this arbitration.

8 October 2026

Counsel for the Claimant