Litigation & Arbitration Lawyers in Poland
Dudkowiak & Putyra represents foreign companies in disputes in Poland – before the civil and commercial courts at every level, the administrative courts and arbitral tribunals in Poland and abroad, as claimants and as defendants. The firm was founded in 1991 as a litigation firm by two former judges, Andrzej and Grażyna Dudkowiak, who remain its Senior Partners. Its Litigation & Arbitration Practice is led by Anna Szymielewicz, Attorney (radca prawny) and Partner.
Behind the practice stands a one-stop shop for foreign investors in Poland: more than 100 people in offices in Warsaw, Kraków, Poznań and Zielona Góra, including more than 50 lawyers in corporate, tax, IP, employment, real estate and criminal law who join a dispute when it needs them. In the Rzeczpospolita Law Firm Ranking 2026 the firm is the 13th largest Polish law firm outside the international networks by number of advocates and attorneys.
Most of our litigation clients are based outside Poland. Proceedings are run in Polish and reported in English; we also work in German, Spanish, Italian and French. Most matters are conducted under a power of attorney, without travelling to Poland. We handle commercial and contract disputes, domestic and international arbitration, interim relief and asset freezing, the enforcement of foreign judgments and arbitral awards, shareholder and post-M&A disputes, and claims against the State and regulators. Our partners also give expert evidence on Polish law to courts in England and Wales, the Netherlands and Norway.
814
Court and contentious mattersopened between January 2023 and October 2026
for 339 clients, 88% of them from abroad
Litigation team
12
litigation lawyers, backed by more than 50 lawyers in the firm’s supporting practices
Average claim, 2026
PLN 4.2m
average value of the disputes we opened in 2026 (claims of PLN 50,000 or more)
Highest claim
EUR 500m
arbitration for a German mining investor, now being filed
Largest settlement in 2026
USD 40m
court settlement for a Georgian coal trader, reached within weeks of the first filing
Cross-border
90%
of our disputes have a cross-border element – a foreign party, foreign law or enforcement abroad
Client countries
61
countries our litigation clients come from – led by the United Kingdom, the United States, the Netherlands and Germany
Outcomes
73%
of our resolved civil and commercial disputes were won, settled, paid or recovered
Figures: Dudkowiak & Putyra matter records (DP-Stats), January 2023 – October 2026. Sources and methodology.
Litigation and arbitration team
Twelve litigation lawyers – four partners, two of them former judges, three counsel and five associates – led by Anna Szymielewicz. The matters each lawyer has handled are described on their profiles.
Leadership
Anna SzymielewiczAttorney (radca prawny), Partner · Head of Litigation & Arbitration
Head of the practice and a partner since 2021; commercial litigator. Admitted as an attorney-at-law in 2017.
- Commercial litigation and arbitration for international clients, in Polish and English
- Transport and aviation disputes for airlines (KLM, Air France, Transavia and one of the world’s five best airlines in the Skytrax ranking) and logistics operators (Maersk)
- Recourse and reinsurance claims for insurers (Chubb, AXA, AIG)
- Enforcement of foreign judgments and cross-border inheritance disputes; expert evidence on Polish law before the courts in London
Law, Adam Mickiewicz University in Poznań; postgraduate studies in personal data protection (WSB) · Poznań Chamber of Attorneys-at-Law · English
Andrzej DudkowiakBarrister (adwokat), Senior Partner · former judge
Civil and commercial litigator; co-founder of the firm, former judge and head of the commercial division of the court in Zielona Góra. Admitted as an advocate in 1991, after practising as an attorney-at-law (radca prawny).
- Construction and development disputes
- Commercial and administrative litigation, including tax disputes
- Zoning, infrastructure and investment disputes
- Cassation appeals before the Supreme Court and the Supreme Administrative Court
Law, University of Wrocław · Zielona Góra Bar Association
Litigators
Grażyna DudkowiakBarrister (adwokat), Senior Partner · former judge
Grzegorz ŻochowskiBarrister (adwokat), Partner
Marta OleśkowskaBarrister (adwokat), Senior Counsel
Michał SzczepaniakAttorney (radca prawny), Counsel
Michał MarciszonekBarrister (adwokat), Counsel
Zuzanna RudzińskaAssociate · trainee lawyer
Dominika KozińskaAssociate · trainee lawyer
Karolina DudkowiakAssociate · trainee lawyer
Maria NarożnaAssociate · trainee lawyer
Zuzanna KrysaAssociate · trainee lawyer
Practice areas and background of each litigator
Grażyna DudkowiakBarrister (adwokat), Senior Partner · former judge
Civil litigator; co-founder of the firm and former judge of the civil division of the court in Zielona Góra. Admitted as an advocate in 1996.
- Divorce and the division of marital assets
- Succession disputes and the division of estates
- Family cases with an international element
Law, Adam Mickiewicz University in Poznań (with distinction) · Zielona Góra Bar Association
Grzegorz ŻochowskiBarrister (adwokat), Partner
Commercial litigator. Admitted as an advocate in 2016.
- Commercial and contract disputes
- Disputes of transport companies
- Debt recovery
- Administrative and tax litigation
Law, University of Wrocław · Zielona Góra Bar Association · English
Marta OleśkowskaBarrister (adwokat), Senior Counsel
Civil and commercial litigator with a large private-client practice. Admitted as an advocate in 2019.
- Civil and commercial disputes
- Cross-border succession cases – trusts, estates in several jurisdictions, foreign wills
- Division of assets and estates between individuals
- Negotiation, mediation and court and out-of-court settlements
Law, Adam Mickiewicz University in Poznań · Poznań Bar Association · English
Michał SzczepaniakAttorney (radca prawny), Counsel
Civil and commercial litigator. Admitted as an attorney-at-law in 2024.
- Contractual claims and commercial disputes
- International debt recovery
- Family and succession disputes
Michał MarciszonekBarrister (adwokat), Counsel
International commercial litigator. Admitted as an advocate in 2023.
- Transport and insurance claims
- Construction disputes
- Division of assets
- Court and out-of-court settlements
Poznań Bar Association
Zuzanna RudzińskaAssociate · trainee lawyer
Commercial litigator; trainee attorney.
- Air passenger claims (Regulation 261/2004, Montreal Convention)
- CMR cargo claims
- Claims and recovery
Dominika KozińskaAssociate · trainee lawyer
Civil and commercial litigator; trainee attorney.
- Claims and recovery
- Succession and estate matters
Karolina DudkowiakAssociate · trainee lawyer
Civil and commercial litigator; trainee attorney.
- Civil and commercial litigation
Maria NarożnaAssociate · trainee lawyer
Civil litigator; trainee attorney.
- Civil disputes
- Family and succession law
Zuzanna KrysaAssociate · trainee lawyer
Commercial litigator; trainee attorney.
- Claims and recovery
- Intellectual-property disputes
More than 50 lawyers from the firm’s other practices – commercial, market entry, corporate, IP, tax, criminal, real estate and employment – join a dispute when it needs them, and we coordinate sworn translators, court experts, bailiffs and foreign counsel, so you keep one point of contact. See the supporting practices
Litigation and arbitration services in Poland
01Dispute strategy, pre-action and settlementMerits, forum, cost, conciliation, mediation
Deciding whether, where and how to litigate in Poland
Before recommending proceedings we look at more than the merits: the evidence available, the forum, the cost and time to judgment, the other side’s finances and assets, and whether a judgment can actually be enforced. Often the best result comes before a full trial – a conciliation summons that stops the limitation clock and brings the other side to the table, court-annexed mediation, or a settlement that becomes an enforceable title the day it is approved. Where the dispute spans several countries we build one settlement for all of them.
What we do
- Full case analysis as a separate engagement, in English – merits, evidence, forum, cost, duration, enforcement prospects and realistic recovery
- Strategy building – the order of steps, interim relief, parallel proceedings and settlement windows
- Mock litigation – testing the case, the witnesses and the expert evidence before the real hearing
- Choice of forum and law – Polish court, a court abroad or arbitration; jurisdiction and choice-of-law clauses under Brussels I bis and Rome I
- Conciliation summonses (zawezwanie do próby ugodowej) – interruption of limitation and a court-approved settlement with the force of a judgment
- Negotiation, mediation and court-annexed mediation; multi-jurisdiction settlements
- Litigation budgets by stage, reputational risk and communication during a dispute
Selected experience
- A Georgian coal trader: three conciliation summonses against a Polish coal buyer and a court settlement for approximately USD 40 million on a claim of approximately USD 46 million (July 2026), with a counterclaim of approximately USD 17 million repelled
- Łukasiewicz Research Network – Institute of Aviation v Airbus Poland: the claim for an ABS system for the PZL-130 Orlik trainer resolved through court-annexed mediation and paid in full (2020–2023)
- A Czech gaming-software company: after a default judgment won by Poland’s state lottery operator, a settlement turned the dispute into a new contract to upgrade 240 gaming terminals; the judgment was set aside (2026)
- A German e-bike leasing company: a cargo-theft claim with Polish, Czech and German elements settled before litigation, with a repayment schedule that is being performed (2024–2025)
- OS Production group: one master settlement agreement splitting an international exhibition-stand group across five jurisdictions – share swaps, brands and domains – and the withdrawal of the Polish claim (2017–2019)
02Commercial and contract litigationSupply, distribution, penalties, termination, lost profits
Supply, distribution, construction and service contract disputes
Most of our disputes are about contracts between companies from different countries: unpaid invoices that the buyer meets with set-offs and penalties, a long-term supply contract terminated overnight, a project in which each side blames the other. We act on both sides – as claimant and as defendant – before the district and regional courts, the courts of appeal and the Supreme Court, and we combine Polish law with the CISG and the governing foreign law where the contract requires it.
What we do
- Claims for price, damages and lost profits; contractual penalties, set-off and retention; termination and withdrawal from contracts
- Defence of claims against foreign suppliers, contractors and service providers in Poland
- Construction and infrastructure disputes – subcontractors, the investor’s liability (Article 647¹ of the Civil Code), performance bonds and substitute performance
- Appeals and cassation appeals to the Supreme Court; challenges to the jurisdiction of Polish courts
- Commercial disputes involving the personal rights and reputation of companies, and non-compete claims – set-off after the 2023 reform, retention rights
Selected experience
- ADÖKSAN (Turkey and Hungary) v BorgWarner eMobility Poland: three Warsaw claims for approximately EUR 10 million and lost profits after the termination of long-term supply contracts for Audi, Daimler and DAF projects (2025–2026)
- Karamtara Engineering (India) v ELBUD: transmission towers for a PSE 400 kV line – approximately PLN 9 million claimed and approximately PLN 13 million in penalties and CBAM costs resisted, with the right to suspend deliveries under the CISG (2026)
- Opoura (Denmark) v a state-owned energy group: defence of a wind-farm SCADA provider against a claim of approximately PLN 4 million, relying on the contractual exclusion of lost profits (2025–2026)
- Optarget v Polskie Radio: LED screens for the national radio broadcaster – a Supreme Court judgment on the classification of the contract and approximately PLN 500,000 with interest from 2013 (2012–2021)
- An Italian food company: a claim against our client rejected for lack of Polish jurisdiction – a forum clause printed on invoices is not a jurisdiction agreement (2024; the claimant’s appeal pending)
- A UK formwork supplier: a construction supplier’s claim against our client dismissed in full at both instances (2023–2024)
03Domestic and international arbitrationSA KIG, Lewiatan, ICC, LCIA, SCC, VIAC
Arbitration seated in Poland and Polish parties in arbitration abroad
We represent claimants and respondents before the Court of Arbitration at the Polish Chamber of Commerce (SA KIG) and the Lewiatan Court of Arbitration, in ICC, LCIA, SCC and VIAC proceedings and in ad hoc arbitration, in English or Polish. We advise on arbitration clauses before a dispute arises, act in the proceedings in support of arbitration before Polish courts – interim measures, appointment of arbitrators, jurisdiction – and in applications to set aside or to recognise and enforce awards.
What we do
- Arbitration clauses and their amendment once a dispute has arisen
- Representation in institutional and ad hoc arbitration – pleadings, witnesses, party-appointed experts, hearings in English
- Court proceedings in support of arbitration – interim measures, appointment and challenge of arbitrators
- Applications to set aside awards and their defence (Articles 1205–1211 of the Code of Civil Procedure)
- Recognition and enforcement of awards in Poland and abroad – our Arbitration Guide in Poland
Selected experience
- HMS Bergbau AG (Germany): an arbitration claim of approximately EUR 500 million over obstacles to its entry into the Polish coal-mining market, now being filed (2026)
- A Saudi food-distribution group: English-language arbitration at SA KIG under the UNIDROIT Principles – an IT developer’s claim dismissed in full and costs awarded to our client (2021–2023)
- A Ukrainian building-materials supplier v the operator of an international DIY chain in Poland: SA KIG arbitration over unpaid invoices out of more than 1,000, arguing that Ukrainian currency law bars the set-offs applied (2022–2026)
04Interim relief and asset freezingAccount freezes, compulsory mortgages, injunctions
Securing a claim before and during the proceedings
A judgment is only worth what can be recovered under it. Polish courts can freeze bank accounts, register a compulsory mortgage, prohibit the sale of shares or property, or order a party to keep a contract in force – before the claim is filed and without warning the other side. Of the 26 applications decided in our files since 2023, 18 were granted; the fastest freeze came six days after filing. We also defend clients against security orders that block their business.
What we do
- Freezing orders over bank accounts, receivables and movable assets; compulsory mortgages over real estate
- Injunctions securing non-monetary claims – keeping a contract, an account or a supply in force, prohibiting the disposal of assets
- IP injunctions – prohibiting the use of an infringing trademark or designation, the sale of infringing goods or the use of trade secrets for the duration of the proceedings
- Pre-action security – the claim must then be filed within the deadline set by the court, usually two weeks
- Securing evidence, including by a court bailiff – securing evidence by a bailiff
- Defence against security orders – complaints, applications to lift or limit them, security for damages
Selected experience
- ZELMER – B&B Trends (Spain): an injunction prohibiting Zelmotor from using the ZELMOTOR designation for the duration of the trademark proceedings (decision of the Regional Court in Warsaw, XXII GWo 81/21)
- An Irish investor: compulsory mortgages over shares in two properties of a residential developer granted 61 days after the application, securing approximately EUR 1 million (2026)
- A Singapore advertising company: accounts of a payment institution whose licence had been revoked frozen with the claim, followed by a payment order for approximately USD 235,000 and EUR 110,000 (2025)
- Quicko v Alior Bank: an injunction against the AML-driven termination of 41 bank accounts of a currency exchange office (2023–2025)
- Dniproavia (Ukraine) v LOT Aircraft Maintenance Services: the Court of Appeal lifted a security order covering eight of the airline’s aircraft and discontinued the security proceedings (2017) – report by Misechko & Partners
05Foreign judgments and arbitral awardsRecognition, enforceability, New York Convention
Turning a judgment or award from abroad into money in Poland – and the reverse
Judgments from EU Member States are enforced in Poland without a declaration of enforceability (Brussels I bis) and go straight to the bailiff. Everything else needs a Polish court: judgments from outside the EU under the Lugano Convention, the 2019 Hague Convention (in force for the United Kingdom), bilateral treaties or Articles 1150–1151 of the Code of Civil Procedure, and arbitral awards under the New York Convention. We apply for recognition and enforceability, defend against it, and coordinate the enforcement of Polish judgments abroad.
What we do
- Declarations of enforceability of judgments from outside the EU – UK, US, Switzerland, China, the Middle East – and of foreign settlements and notarial deeds
- Recognition and enforcement of foreign arbitral awards (New York Convention; Articles 1212–1217 of the Code of Civil Procedure), including awards based on arbitration agreements concluded by e-mail
- Defence against recognition – public policy, service, jurisdiction, validity of the arbitration agreement
- Enforcement of Polish judgments and payment orders abroad, with local counsel
- Guides: enforcement of foreign rulings in Poland, the UK and the 2019 Hague Convention, recognition of arbitral awards
Selected experience
- A petrochemical producer: an application to declare enforceable in Poland the civil award of approximately EUR 9 million made by a Tehran criminal court against a fraudster living in Poland (2025–2026)
- A Chinese clothing exporter: recognition of an SCC award for more than USD 200,000 against a Łódź wholesaler, defending an arbitration agreement concluded by exchanging scanned documents (2024–2026)
- Austria Juice (AGRANA group): enforceability of a VIAC award for approximately PLN 5.6 million and costs, followed by a claim against the debtor’s former CEO (2017–2019)
- A Polish household-appliance manufacturer: a final Polish payment order against a Chinese machinery supplier enforced in China under the 1987 Poland–China treaty, with Shanghai counsel (2023–2026)
- Kalisz Municipal Roads Authority: enforcement in Romania of Polish judgments for approximately PLN 1.1 million plus interest (2023)
06Corporate, shareholder and post-M&A disputesResolutions, deadlock, share deals, warranties
Disputes between shareholders, with management and after a transaction
Shareholder disputes in Polish companies are decided fast or not at all: a resolution must be challenged within weeks, a deadlocked board can paralyse a subsidiary, and a share deal that went wrong can leave the buyer with warranty claims and the seller with unpaid instalments. We act in these disputes with our corporate team, and in post-acquisition claims with the M&A lawyers who know how the transaction documents were negotiated.
What we do
- Challenges to shareholder resolutions; deadlock and exit; exclusion of a shareholder
- Post-M&A disputes – warranties and indemnities, earn-outs, price adjustments, deferred payments, assignments of receivables
- Claims by the company against directors (Article 293 of the Commercial Companies Code) and disputes over directors’ duties
- Disputes over shares, assignments and corporate control, including where sanctions affect the shareholder
- Division of partnership assets and shareholdings inside an estate – with our inheritance team
Selected experience
- An investor: analysis of claims arising from the sale of 100% of the shares for approximately EUR 18 million, assignments of receivables and the effect of sanctions on the transaction (2025–2026)
- Foreign heirs: division of the assets of a former partnership worth approximately PLN 43 million inside an estate; a third party’s claimed assignment rejected (2026, appeal pending)
07Disputes with the State and regulatorsPenalties, administrative courts, sanctions, investor–State
Penalties, decisions and the administrative courts
Foreign companies in Poland meet the State as regulator, as customs and tax authority and as a commercial counterparty. We challenge penalties and decisions before the authorities and the administrative courts – the regional administrative courts (WSA) and the Supreme Administrative Court (NSA) – and act in disputes with state-owned companies and funds. In 2025 one of our cases led the Supreme Administrative Court to hold the Polish PNR Act incompatible with EU law for intra-EU flights.
What we do
- Administrative penalties – Border Guard, transport and road inspectorates, the energy, telecoms and rail regulators – appeals against penalties
- Complaints and cassation appeals before the WSA and NSA; complaints about inaction
- Competition and regulatory proceedings – UOKiK, UTK, URE, UKE – with our administrative law practice
- Concessions, environmental decisions and mining licences; EU sanctions – release of frozen goods and payments
- Investor–State disputes – notices under the Energy Charter Treaty and bilateral investment treaties; claims against state funds, including Polish Development Fund COVID-19 subsidies
- Customs and tax disputes with our tax practice
Selected experience
- Numerous international airlines v the Border Guard – PNR penalties: in June 2025 the Supreme Administrative Court held the application of the PNR Act to all intra-EU flights incompatible with EU law; the Border Guard then closed all 243 proceedings against one of our carriers without a fine
- HMS Bergbau and Silesian Coal: the Supreme Administrative Court set aside the environmental decision for the Orzesze coal deposit of 543 million tonnes (III OSK 917/22, June 2025)
- RegioJet (Czech Republic): proceedings before UOKiK and the rail regulator over access to infrastructure and stations and alleged predatory pricing by the PKP group (2026)
- A Chinese vehicle manufacturer and its Polish distributor: release of 455 vehicles frozen under EU sanctions, applying the General Court’s judgment in T-494/22 (2025)
- A Poznań-based Polish manufacturer v the Polish Development Fund: a COVID-19 subsidy of approximately PLN 2.1 million reclaimed by the fund – a test case for Polish businesses (2024–2026)
08Fraud, asset tracing and recoveryBEC, frozen accounts, victims in criminal cases
Getting money back after fraud – civil and criminal tracks together
When a payment goes to a fraudster’s account, the first days decide whether anything comes back. We file the criminal complaint with a request to block the account, join the proceedings as the injured party or auxiliary prosecutor, claim compensation within the criminal case, and run the civil claim and asset tracing in parallel – with our criminal law team and with counsel abroad where the assets have moved.
What we do
- Business e-mail compromise and invoice fraud – emergency account blocks (Article 106a of the Banking Law) and criminal complaints within days
- The injured party in criminal proceedings – auxiliary prosecutor, compensation orders (Article 46 of the Criminal Code), access to the file
- Agreements between several victims on the distribution of frozen funds
- Forged documents and promissory notes – suspending enforcement, handwriting experts, reopening investigations
- Cross-border asset tracing and protective seizures abroad with local counsel
Selected experience
- UK Global Healthcare (UK): auxiliary prosecutor in a fraud case of approximately USD 3.75 million; an agreement among all four victims on sharing approximately USD 2.2 million frozen in the proceedings, with about 95% for our client (2020–2026)
- A world-renowned Danish company: approximately EUR 820,000 sent to a mule company after the impersonation of a Korean supplier – accounts blocked and a compensation claim in the criminal case (2021–2026)
- An Italian industrial group: approximately EUR 380,000 paid to a fraudster – a criminal complaint with a request to block the account within days and a draft settlement with the UK agent
- A collector of classic cars: a limited-edition car worth approximately EUR 150,000 moved from Poland to France – civil and criminal proceedings in Poland and a protective seizure order from a French enforcement judge (2026)
- A Chinese national: a forged promissory note for approximately PLN 850,000 exposed by a handwriting expert, enforcement halted and the investigation reopened by the court (2024)
09IP, brand and unfair-competition litigationTrademarks, copyright, trade secrets
Protecting trademarks, works and know-how in Polish courts
IP disputes are won by speed and by evidence of market confusion. We obtain pre-action injunctions, bring claims for infringement of EU and Polish trademarks, copyright and designs and for acts of unfair competition, claim the surrender of profits and damages, and follow the infringer into its restructuring or criminal proceedings – together with our IP practice.
What we do
- Infringement of EU trademarks (Article 9 of the EU Trademark Regulation) and Polish trademarks (Article 296 of the Industrial Property Law)
- Unfair competition – misleading designations, trade secrets, parasitic marketing (Unfair Competition Act)
- Copyright and design disputes, including software and computer games
- Pre-action injunctions, claims for the surrender of profits, defence against invalidity actions
- Brand protection when the infringer restructures or goes bankrupt; criminal complaints
Selected experience
- ZELMER – B&B Trends (Spain) and its distributor v Zelmotor: a pre-action injunction, an injunction claim valued at approximately PLN 14 million and a claim for the surrender of profits; after our appeals the court refused to approve Zelmotor’s arrangement with creditors (2025)
- An international games studio: trade secrets and copyright in a game-development dispute
10Transport, aviation, insurance and trade claimsCMR, ACMI, EU261, subrogation, CISG
Cargo, aircraft, insurance recovery and cross-border sales of goods
Our largest sector practice. We act for airlines, operators and maintenance providers, for carriers, forwarders and cargo owners, for insurers and reinsurers recovering what they have paid, and for exporters and importers in disputes under the CISG. The issues are specific – the CMR and Montreal Conventions, Regulation 261/2004, ACMI and wet-lease contracts, subrogation under Article 828 of the Civil Code – and so are the courts’ habits; we know both.
What we do
- Aviation – ACMI, wet and dry lease, maintenance and aircraft-damage disputes; defence of airlines in passenger-claims portfolios (Regulation 261/2004, Montreal Convention) and against claims agencies – EU261 and air traffic control, strikes and armed conflicts
- Road, rail and sea transport – CMR, cargo theft, the carrier’s gross negligence, forwarders’ and customs agents’ liability, COTIF; ship-repair disputes under BIMCO terms
- Insurance and reinsurance recovery – subrogated recourse claims after payout, assignments of claims to insurers, coverage disputes – insurance law in Poland
- International trade – CISG sales, defective goods and recalls, letters of credit and documentary disputes, cross-border distribution
Selected experience
- A Slovak airline v a Polish charter carrier: a claim of approximately EUR 11 million under an ACMI agreement for two Boeing 737-800 aircraft, under Slovak law (2021–2026)
- One of the world’s largest insurance groups, as cargo insurer of a multinational tobacco manufacturer, v a global logistics operator: a recourse claim of approximately PLN 9.3 million after the theft of a cigarette shipment, reinstated by the Court of Appeal in August 2026
- Two leading international airlines, including one of the world’s five best (Skytrax 2026): lead litigation counsel in Poland for passenger-claims portfolios – from claim assessment and ADR to all instances (2021–2026)
- An aircraft operator: damage to a Bombardier aircraft at a Polish airport and its downtime – a claim of approximately EUR 1.5 million; a European rail-wagon lessor: thefts of brake systems from 23 tank wagons
- An Irish beverage company: a CISG claim against a Polish producer that filled cans with an energy drink instead of a soft drink – price, recall costs and lost profits (2023–2026)
- A Ukrainian distributor: damages from a Polish customs agent whose wrong transit declaration left a cargo detained until it expired (2023–2026)
11Expert opinions on Polish lawForeign courts, tribunals and institutions
Polish law for foreign courts, tribunals and institutions
Courts and arbitral tribunals abroad regularly need evidence of Polish law, and foreign law firms, insurers and institutions need an opinion they can rely on. Our partners give expert opinions and evidence on Polish civil, commercial and procedural law, and have done so in proceedings before the courts of England and Wales, the Netherlands and Norway. We also prepare legal opinions for Polish and foreign courts and public institutions, and act as local counsel in Poland for international law firms, in-house teams, trustees and estate administrators.
What we do
- Expert reports and joint statements on Polish law, and testimony at hearings (CPR Part 35 and equivalent procedures)
- Witness statements on Polish law and procedure – jurisdiction, related proceedings, limitation, company and insolvency law
- Legal opinions for courts, arbitral tribunals, regulators and other institutions
- Local counsel for foreign law firms – Polish proceedings run to your timetable, the client relationship stays with you
- Coordination of parallel proceedings in Poland and abroad, service of documents and the taking of evidence
Selected experience
- Michał Dudkowiak: witness statements on Polish law before the High Court of Justice, recorded in Euroeco Fuels (Poland) Ltd v Szczecin and Świnoujście Seaports Authority, [2018] EWHC 1081 (QB), paragraphs 48 and 77 – the court declined jurisdiction under Article 30(2) of Brussels I bis in favour of related Polish proceedings
- Anna Szymielewicz: expert on Polish company law before the London Circuit Commercial Court in proceedings arising from an LCIA arbitration, on the transfer of an arbitration agreement when a sole trader is converted into a company (2024–2025)
- Piotr Putyra: expert on Polish law before the courts in the Netherlands
Disputes by industry
Disputes arise in every sector; these are the sectors in which most of ours arise, and the disputes we see most often in each.
AviationACMI, leasing, maintenance and passenger claims
Wet- and dry-lease and ACMI disputes, maintenance and aircraft-damage claims, air passenger claims under Regulation 261/2004 and the Montreal Convention, and penalties imposed on carriers.
Transport, logistics and shippingCargo, carriers and forwarders
CMR claims, cargo theft and the carrier’s gross negligence, disputes between carriers, forwarders and customs agents, freight and demurrage, ship repair.
Insurance and reinsuranceRecourse, subrogation and coverage
Insurers’ recourse claims after payout, assigned claims, reinsurance recoveries, coverage disputes and claims against liability insurers.
Construction and infrastructureContractors, subcontractors and investors
Contractual penalties, acceptance and defects, the investor’s liability to subcontractors, performance bonds, substitute performance and grid and energy projects.
Energy, mining and commoditiesSupplies, licences and projects
Automotive and manufacturingSupply chains and tooling
Termination of long-term supply contracts, tooling and stock, defective components, lost profits and product liability.
Food, beverages and FMCGSales of goods and retail chains
CISG sales, quality claims and recalls, disputes with retail chains over set-offs, rebates and contractual advantage.
Real estateProperty, leases and developers
Compulsory mortgages, disputes with developers, industrial and commercial leases, land-register and co-ownership disputes.
Financial services and fintechBanks, payment institutions and investors
Termination of bank accounts, funds frozen by payment institutions, claims in the insolvency of financial firms and investor disputes.
Technology, telecoms and gamingIT projects and digital services
Failed software and IT implementations, wholesale access between operators, platform and e-commerce disputes, software and game copyright.
RailAccess, regulators and rolling stock
Access to infrastructure and stations, proceedings before the rail and competition regulators, damage to and maintenance of rolling stock.
International trade and defenceSanctions and strategic goods
Goods and payments frozen under EU sanctions, export-control and customs decisions, cross-border distribution and agency disputes.
Who we act for
Foreign companies in PolandSuppliers, buyers and investors from the EU, the UK, the US and Asia
“Our Polish customer stopped paying and now says the goods were defective.”
Insurers and reinsurersCargo, property and liability insurers recovering what they have paid
“We have paid the claim – can we sue the carrier in Poland, and under which law?”
Airlines and aviation businessesCarriers, operators, lessors and maintenance providers
“Three hundred passenger claims a year and a Border Guard penalty for every flight.”
Transport companiesCarriers, forwarders, logistics and shipping groups
“The cargo was stolen on the way to Warsaw – who pays, and under which convention?”
Industrial supply chainsAutomotive, energy and infrastructure suppliers on Polish projects
“They terminated a ten-year supply contract with three months’ notice.”
Investors against the StateHolders of licences, concessions and decisions challenged or revoked
“The ministry has blocked our project – what can the courts do, and what can the treaty do?”
Foreign law firms and in-house teamsCounsel who need a Polish team, an expert or a local court
“We need evidence of Polish law for a hearing in London next month.”
Shareholders and buyersPartners in deadlocked companies and buyers after an acquisition
“The other shareholder passed a resolution without us.”
Victims of fraudCompanies whose payment went to a fraudster’s account in Poland
“We paid EUR 800,000 to what we thought was our supplier’s new account.”
Research institutes and public bodiesInstitutes, municipal authorities and state-owned counterparties
“Our contractor went abroad and stopped paying – can a Polish judgment follow it?”
Litigation and arbitration in Poland – selected matters
A selection of our largest and most instructive matters from 2017–2026. Figures and dates are taken from the case files; where a matter is still pending, we say so.
Commercial dispute · energy and commodities · 2026
A Georgian coal trader: a USD 40 million settlement – and the fight to enforce it
A coal trader from Tbilisi was owed approximately USD 46 million by a Polish buyer for coal deliveries. Instead of a years-long trial, Dudkowiak & Putyra filed three conciliation summonses and obtained a court settlement for approximately USD 40 million in July 2026, payable within 21 days, while repelling the buyer’s counterclaim of approximately USD 17 million. On the day the court granted the enforceability clause, the buyer filed for bankruptcy and opened restructuring proceedings to freeze enforcement. We applied to lift the effects of the restructuring under Article 226f of the Restructuring Law and traced the buyer’s assets.
Mining · investor and the State · 2021–2026
HMS Bergbau: winning against the environmental regulator
Silesian Coal, the Polish subsidiary of the German listed HMS Bergbau AG, held rights to the Orzesze deposit – 543 million tonnes of coal, over 40% of it coking coal. After the General Director for Environmental Protection issued an adverse decision in 2021, we took the case through the Regional Administrative Court to the Supreme Administrative Court, which set aside both the judgment and the decision in June 2025 (III OSK 917/22; notice of the General Director, 26 August 2025). For the investors we also served notice on the State under the Energy Charter Treaty and the Poland–Switzerland BIT, and are now filing an arbitration claim of approximately EUR 500 million; a related licence case is before the NSA.
Aviation · Slovak law · 2021–2026
A Slovak airline v a Polish charter carrier: an ACMI dispute under foreign law
A Slovak airline leased two Boeing 737-800 aircraft with crews to a Polish charter carrier under a 2020 ACMI agreement. When the carrier relied on COVID-19 as force majeure and stopped paying, we sued in Warsaw, first through a European Payment Order and then in full proceedings under Slovak law and Brussels I bis. The claim has been extended to approximately EUR 11 million; the witnesses have been heard and we have applied for an expert on Slovak law.
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Automotive · supply contracts · 2025–2026
ADÖKSAN v BorgWarner eMobility Poland: three claims after the end of a supply relationship
ADÖKSAN, a Turkish aluminium foundry, and its Hungarian subsidiary supplied castings for Audi, Daimler and DAF projects to BorgWarner’s Polish plant. After BorgWarner terminated the contracts in June 2025, we filed three claims in the Regional Court in Warsaw – for the Turkish invoices, the Hungarian invoices and stock and tooling – worth approximately EUR 10 million together, with applications for asset freezes, and prepared a critical analysis of the damages report behind the lost-profit claim. One claim is in mediation; we have asked the court to join the files so that one settlement covers all of them.
Aviation · administrative courts · 2023–2025
The PNR test cases: airlines v the Polish Border Guard
The Polish Border Guard fined airlines PLN 40,000 per flight for failing to transfer passenger name record (PNR) data – including on flights inside the EU. We challenged the penalties for numerous international airlines, from private-aviation operators to scheduled carriers. In June 2025 the Supreme Administrative Court held, in our test cases (II GSK 2333/24), that applying the PNR Act to all intra-EU flights without a real terrorist threat is incompatible with the Court of Justice’s judgment in C-817/19, and set aside the judgment and both decisions. In November 2025 the Border Guard closed the last 50 of 243 proceedings against one of our airline clients without a fine; Parliament amended the PNR Act in July 2025.
Insurance recovery · logistics · 2023–2026
One of the world’s largest insurers v a global logistics operator: recourse after cargo theft
One of the world’s largest insurance groups paid a multinational tobacco manufacturer for a stolen shipment of cigarettes – most of the loss being excise duty – and took over its claim against the logistics operator. We filed a recourse action for approximately PLN 9.3 million and joined the criminal case. The Regional Court rejected the claim on an English jurisdiction clause in the policy; in August 2026 the Court of Appeal set that ruling aside and the case returns to Warsaw.
IP litigation · consumer goods · 2021–2026
ZELMER v Zelmotor: trademark protection on three fronts
For B&B Trends of Spain, owner of the ZELMER household-appliance brand, and its distributor we obtained a pre-action injunction in 2021 and sued for infringement of the EU and Polish trademarks and unfair competition, with consumer surveys and misdirected complaints as evidence – an injunction claim valued at approximately PLN 14 million and a claim for the surrender of profits. During the proceedings the court prohibited Zelmotor from using the ZELMOTOR designation (decision of the Regional Court in Warsaw, XXII GWo 81/21). When Zelmotor sought an arrangement with its creditors, our appeals led the Regional Court in Rzeszów to refuse its approval in May 2025 (RZ/Gz-KRZ/64/2024).
Construction · Supreme Court · 2012–2021
Optarget v Polskie Radio: to the Supreme Court and back
Optarget supplied and installed LED screens for Polish Radio, which refused to pay and argued that the claim was time-barred. We kept the claim alive with conciliation summonses and took it through the appeal to a cassation appeal. In November 2019 the Supreme Court held (I CSK 477/18) that the contract was a construction contract with a three-year limitation period; after the retrial the Court of Appeal awarded the balance in February 2021 – in total approximately PLN 500,000 with interest from 2013, about 96% of the claim.
Arbitration · technology · 2021–2023
A Saudi food-distribution group: an English-language arbitration at the Polish Chamber of Commerce
A Polish software house claimed payment from a food-distribution group from Saudi Arabia for a mobile app and an ERP system that did not work. In English-language proceedings before the Court of Arbitration at the Polish Chamber of Commerce, decided under the UNIDROIT Principles, the tribunal dismissed the claim in full in March 2023 and awarded our client its costs.
Fraud and asset recovery · healthcare · 2020–2026
UK Global Healthcare: tracing approximately USD 3.75 million paid to fraudsters
In November 2020 UK Global Healthcare, a UK supplier to the NHS, paid approximately USD 3.75 million to a Polish company in what turned out to be a fraud. Approximately USD 2.2 million was frozen on the fraudsters’ accounts. To avoid years of competing claims, we brokered an agreement among all four victims on sharing the frozen funds, with about 95% for our client, and applied for their release before the criminal case ends.
Supporting practices – one firm for every track of a dispute
A large dispute rarely stays in one court: the contract claim comes with a criminal complaint, a tax assessment, a regulator or a shareholder fight. Our litigation team works with more than 50 lawyers in the firm’s other practices – in the same offices, on the same file. One person leads each practice for litigation clients.
Commercial and regulatoryMichał Puk · 7 lawyers
Michał Puk – Barrister (adwokat) · Supervising Partner, Commercial and Regulatory
Contract, commercial and regulatory disputes
Supply, distribution and service contracts, contractual penalties and termination, high-value commercial negotiations, regulatory and licensing proceedings, competition and consumer cases, defence and dual-use goods.
Market entry and foreign investmentMichał Dudkowiak · 2 lawyers
Michał Dudkowiak – Barrister (adwokat) · Managing Partner, Market Entry & Foreign Investment
Disputes over access to the Polish market
Disputes of foreign investors with Polish counterparties and the State over access to regulated markets, licences and concessions, investor–State claims under investment treaties, foreign-investment control, and expert evidence on Polish law for foreign courts.
Criminal law and white-collar crimePaula Osiecka · 4 lawyers
Paula Osiecka – Barrister (adwokat) · Counsel, Criminal Law
The criminal track of a commercial dispute
Criminal complaints, bank account blocks, the injured party and auxiliary prosecutor in fraud cases, compensation orders, and the defence of managers where a dispute turns criminal.
Tax and customsMarcin Kręglewski · 8 lawyers and tax advisers
Marcin Kręglewski – Barrister (adwokat) · Partner, Head of Tax
Tax, excise and customs disputes
Tax audits and assessments, appeals to the administrative courts, VAT, excise and customs classification disputes, transfer pricing, directors’ liability for tax arrears, and the tax side of settlements and damages.
Intellectual propertyNatalia Chudzicka-Szwajka · 3 lawyers, supervised by Marcin Kręglewski
Natalia Chudzicka-Szwajka – Barrister (adwokat) · Counsel, Intellectual Property
Trademarks, copyright, designs and unfair competition
Trademark and design infringement, invalidity and opposition proceedings, copyright in software, games and media, unfair competition and trade secrets.
Corporate and M&AMichalina Ostrowska · 8 corporate lawyers and 2 corporate assistants
Michalina Ostrowska – Counsel · Head of the Corporate Division
Shareholder and post-M&A disputes
Challenges to shareholder resolutions, disputes between shareholders and with management, post-acquisition warranty and price claims, commercial-register proceedings and the corporate side of a debtor.
Real estateWojciech Kasprzak · 4 lawyers
Wojciech Kasprzak – Attorney (radca prawny) · Senior Counsel, Real Estate
Property, lease and development disputes
Commercial and industrial lease disputes, property purchase disputes, defects and damages, disputes with developers and contractors, compulsory mortgages and enforcement against real estate.
Employment lawAlicja Myśluk-Landowska · 8 employment lawyers
Alicja Myśluk-Landowska – Attorney (radca prawny) · Practice Partner, Head of Employment and Labor Law
Employment disputes
Termination and reinstatement claims, mobbing, harassment and discrimination claims, claims of key managers and non-compete disputes, collective disputes with trade unions, labour inspections.
How we run a dispute
- From your first e-maileverything you tell us is covered by legal professional privilege (attorney–client confidentiality under the Polish bar rules).
- Within 24 hoursa reply from the practice with a fee proposal for the next steps, and any urgent deadline we can see from your e-mail flagged straight away.
- Case analysisonce instructed, a full analysis in English as a separate service – the merits, the forum, limitation, the evidence needed, a realistic timeline, the other side’s assets and the options for settlement – with a budget by stage.
- The proceedingsconciliation or mediation where it pays, interim relief where it is needed, then the claim, the hearings and the appeals – under a power of attorney, with online hearings where available and a report after every step.
- Enforcementthe judgment, award or settlement turned into money – through the bailiff in Poland, recognition abroad or a claim in the debtor’s insolvency – by the lawyers who ran the case.
For referring law firms, in-house teams and insurers
A large part of our litigation comes from foreign law firms, in-house legal teams and insurers whose clients or insured have a dispute in Poland. We run the Polish proceedings, give evidence of Polish law where your court needs it, and report to you on your timetable; the client relationship stays with you. Portfolios of similar claims – passenger claims, cargo claims, insurers’ recourse – are run on agreed reporting and fixed fees per stage.
- One firm, every trackCivil, arbitration, administrative, tax and criminal proceedings in the same dispute, coordinated by one team and one point of contact.
- English as standardFiles are run in Polish and reported in English; the firm also works in German, Spanish, Italian and French.
- Costs you can planHourly billing, hourly packages, fixed or capped fees and budgets for each stage, agreed before the work begins.
Memberships
Dudkowiak & Putyra is a member of the chambers of commerce of the countries most of our litigation clients come from – the British Polish Chamber of Commerce, the Netherlands-Polish Chamber of Commerce and AHK Polska, the Polish-German Chamber of Industry and Commerce – and of two industry associations: FinTech Poland and the Polish New Mobility Association (PSNM).
Working with our litigation practice – questions clients ask
Do you act for foreign companies?
Yes – most of our litigation clients are foreign: 88% of the clients for whom we opened court and contentious matters since 2023 came from outside Poland, from 61 countries, led by the United Kingdom, the United States, the Netherlands and Germany. We act for their Polish subsidiaries and for companies with no presence in Poland at all.
In what language do you work?
English is our standard working language: we report, advise and draft in English. Proceedings before Polish courts are conducted in Polish, and we arrange sworn translations and interpreters. The firm also works in German, Spanish, Italian and French, and arbitration can be conducted entirely in English.
Do we have to come to Poland?
Usually not. We act under a power of attorney, file electronically, request online hearings where the court allows them and report after every step. If a witness or a representative of the client has to be heard, this can often be done remotely.
Who will handle our case?
Each matter is led by a partner or counsel from the litigation team under the supervision of Anna Szymielewicz, Head of Litigation & Arbitration, with one point of contact for the client. Lawyers from the supporting practices join when the dispute touches tax, criminal law, IP, company law or regulation.
How quickly will we hear from you – and is our first e-mail confidential?
We reply within 24 hours with a fee proposal and the next steps. A full analysis of the case – merits, forum, limitation, evidence and budget – is a separate service carried out once you instruct us. Urgent matters, such as an approaching limitation date, an asset freeze or a claim served on you, are handled as a priority; please flag them in your first e-mail. Everything you send us is covered by legal professional privilege from the first contact.
How do you charge for litigation?
We agree the model before the work begins: hourly billing with monthly statements, hourly packages, fixed or capped fees, or a budget for each stage of the proceedings. For portfolios of similar claims we agree fixed fees per stage and a reporting format.
Do you handle arbitration and proceedings outside Poland?
Yes. We act in arbitration before the Polish Chamber of Commerce and Lewiatan courts and in ICC, LCIA, SCC and VIAC proceedings, coordinate parallel proceedings and enforcement abroad with local counsel, and our partners give expert evidence on Polish law to courts in England and Wales, the Netherlands and Norway.
Can you work with our foreign law firm, in-house team or insurer?
Yes. A large part of our work comes from foreign law firms, in-house legal teams and insurers. We run the Polish proceedings and report on your timetable; the client relationship stays with you.
In which industries do most of your disputes arise?
Aviation, transport and logistics, insurance, construction and infrastructure, energy and mining, automotive and manufacturing, food and consumer goods, real estate, financial services, technology and rail.
Where are you based?
Our offices are in Warsaw, Kraków, Poznań and Zielona Góra, and we act before courts throughout Poland.
Questions about Polish procedure, court fees, timelines and enforcement are answered in our Litigation in Poland guide.
Guides and webinars
Guidebook – available on request
Guidebook · Dudkowiak & Putyra · 2026
Litigation in Poland Guidebook
The Polish court system, jurisdiction and choice of court, court fees and recoverable costs, timelines, interim relief, evidence and experts, appeals, arbitration and the enforcement of judgments – for foreign companies and their counsel.
Webinars – November 2026
Webinar · November 2026
Interim orders in Poland – freezing assets before and during a lawsuit
Account freezes, compulsory mortgages and injunctions: what the court needs to see, how fast it decides, and what happens when the other side complains. With examples from our files.
Webinar · November 2026
Insurance and reinsurance recovery in Poland – subrogation and assigned claims
What passes to the insurer on payout under Article 828 of the Civil Code, when an assignment is needed, how reinsurers recover, and which court and law apply to recourse against carriers and contractors.
Video
Litigation in Poland – how Polish courts work
Anna Szymielewicz on the court system, the role of counsel and the costs of proceedings; with a video guide to arbitration in Poland.
Investor Zone
Litigation in Poland guides
The court system and costs, arbitration, insurance law, appeals against penalties, enforcement of foreign rulings, PNR and EU261.
Article
What foreign investors should know about litigation in Poland (IFLR1000)
A practical overview of Polish court proceedings for foreign businesses.
What changed for litigants in 2023–2026
- Amendments to the Code of Civil Procedure in force from 2023 – set-off defences, service and hearings – what’s new in litigation
- Supreme Court on retention rights and on calculating limitation periods (2024) – retention, limitation
- The United Kingdom joined the 2019 Hague Judgments Convention – what it means for UK–Polish disputes
- Supreme Administrative Court on the PNR Act and intra-EU flights (June 2025); amendment of the PNR Act (July 2025) – PNR in Poland
- General Court in T-494/22 – release of payments and goods frozen under EU sanctions
Sources and methodology
Data sources, method and rulings cited
Dudkowiak & Putyra is a Polish business law firm advising foreign investors and their subsidiaries doing business in Poland, founded in Zielona Góra in 1991, with more than 100 people and 66 lawyers, 57 of them advocates and attorneys-at-law. Firm-wide, 84% of clients who signed engagement letters in 2024–2026 came from abroad, from 87 countries. It is the 13th largest Polish (non-network) law firm by number of advocates and attorneys-at-law, based on Rzeczpospolita Law Firm Ranking 2026 data; it is included in the UK FCDO list of lawyers in Poland, and it is profiled in The Legal 500, including Poland – Dispute resolution. More about the firm: About us.
Matter figures: Dudkowiak & Putyra matter records (DP-Stats, extract of 8 October 2026), matters opened between 1 January 2023 and 8 October 2026 in the categories of court and contentious proceedings and debt recovery – 814 matters (77 in 2023, 164 in 2024, 239 in 2025, 334 in 2026 to date) for 339 clients. Client countries as confirmed on 16 October 2026: 88% of clients are from outside Poland, from 61 identified countries. Matter, client and country figures include criminal matters opened in the litigation categories; the analysis of outcomes and durations excludes them. Method: DP-Stats.
Case-file figures: a review of the case files of 423 disputes with at least one matter opened in 2023–2026, 409 of them with documents. Cross-border element: 90% of the 409 disputes. Values: 206 disputes with a stated value, approximately converted to PLN, duplicates removed; the average claim of disputes of PLN 50,000 or more was PLN 4.16 million in 2026 (51 disputes). The EUR 500 million arbitration is shown only as the highest claim and excluded from averages. Outcomes: 61 of 83 resolved civil and commercial disputes ended in a judgment won in full, a settlement, payment or recovery.
Matters are described from the firm’s files (2012–2026). Clients are named where the matter is public – in a published judgment, an official notice or a report by co-counsel, linked in the description – or with their consent; other clients are described by country and sector. Court rulings cited: Supreme Administrative Court, II GSK 2333/24 (June 2025) and III OSK 917/22; Supreme Court, I CSK 477/18; Regional Court in Warsaw, XXII GWo 81/21; Euroeco Fuels (Poland) Ltd v Szczecin and Świnoujście Seaports Authority SA [2018] EWHC 1081 (QB).
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