In Standard Chartered Bank (Hong Kong) Ltd and another v Independent Power Tanzania Ltd and others [2015] EWHC 1640 (Comm), the Commercial Court considered its discretion to grant a stay of proceedings in circumstances where the parties' agreement contained a non-exclusive jurisdiction agreement in favour of the English or Malaysian courts and a forum non conveniens waiver. The court also considered whether it could grant a stay on case management grounds, whether the proceedings were an abuse of process and whether there was a risk of injustice if a stay was refused and related proceedings continued in Tanzania.