Société Nationale Industrielle Aérospatiale v Lee Kui Jak [1987] UKPC 12, [1987] AC 871 is a judicial decision of Privy Council on appeal from Brunei which was for many years, and arguably still is, the leading authority in relation to anti-suit injunctions under the English common law.

Mr Yong's widow tried to sue various parties, including Société Nationale Industrielle Aérospatiale (SNIA) as manufacturer of the helicopter, in the courts of Texas under the Wrongful Death Statute in that state.

[2][3] On 16 December 1980 a Puma 330J helicopter crashed near Kuala Belait, Brunei killing all 12 people on board, including Yong Joon San.

SNIA initially tried to have the action in Texas transferred to the Federal courts, and then sought to stay those proceedings on forum non conveniens grounds.

Both applications were ultimately unsuccessful, and so they sought injunctions in the Brunei courts to restrain the claimants from pursuing the Texas proceedings.

A party could not artificially create a Cambridgeshire type nexus with a proceeding simply by diligently and expeditiously pursuing procedural steps.

Accordingly, SNIA would be unable to claim a contribution from the party who, according to the official accident report, was primarily responsible for the deaths of those on board.

In Trafigura Beheer BV v Kookmin Bank Co [2005] EWHC 2350 (Comm) the court amplified upon the Aérospatiale test, setting out several core propositions:[1]