Originally from Anti-suit Injunctions in International Arbitration 

A.   General Approach

Anti-suit injunction is still very much a Common Law tool and quite new to Civil Law countries with legal traditions rooted in Continental Europe such as France, Turkey, Japan etc.  However, it would not be right to reject these significant measures just because they are not commonly found in Civil Law countries. By taking Turkey as a primary example, the following chapter analyzes why anti-suit injunctions do matter in Continental Europe as well.