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Litigation and Dispute Resolution Chapter for ICLG

N. Pirilides & Associates LLC has contributed to the Litigation & Dispute Resolution 2020 Chapter for International Comparative Legal Guide (ICLG) available at ICLG
 

I. LITIGATION

1 Preliminaries

1.1 What type of legal system has your jurisdiction got? Are there any rules that govern civil procedure in your jurisdiction?
Cyprus is a common law jurisdiction, the legal system being a remainder of the island’s British colonial heritage.  However, the Cyprus legal system can be characterised as a ‘mixed’ legal system with substantive and procedural law based on common law and public law deriving from the civil law tradition.  Civil procedure in Cyprus is regulated by the Civil Procedure Rules (“CPR”).
 
1.2 How is the civil court system in your jurisdiction structured? What are the various levels of appeal and are there any specialist courts?
There are two tiers of Courts in Cyprus: the first tier, which comprises the District and Specialised Courts; and the second tier, which is the Supreme Court of Cyprus.  The Supreme Court acts as the final appellate court, adjudicating upon and finally determining all appeals from the first instance Courts.  Specialised Courts are, inter alia, (i) the Family Courts, (ii) the Employment Tribunal, and (iii) the Rent Control Courts.
 
1.3 What are the main stages in civil proceedings in your jurisdiction? What is their underlying timeframe (please include a brief description of any expedited trial procedures)?
 
The main stages in civil proceedings are the:
 
(1) Filing of pleadings: an action is commenced when a writ of summons has been filed with the Registry of the competent District Court.  A defendant who has been duly served with a writ of summons must enter his appearance in the Registry within 10 days from the service of the writ.  Where a defendant has entered an appearance, he shall file and deliver his defence within 14 days from the time he filed his appearance in the case of a specially endorsed writ, and within 14 days from the filing of the statement of claim in the case of a generally endorsed writ.  Following the filing of the defence, if the plaintiff desires to deliver a reply, he shall file and deliver it within seven days from the delivery of the defence.

(2) Summons for directions: Summons for directions shall be taken out by the plaintiff within 90 days from the time when the pleadings shall be deemed to be closed.  Such directions include, inter alia, discovery and inspection of documents, admission of facts, etc.

(3) Hearings: Following the completion of the “directions” stage, an action is set for hearing.  The trial of actions for claims up to the amount of €3,000 is performed on the basis of the exchange of written witness testimonies in the form of sworn affidavits considered as a fast-track process, whereas in any action for a claim exceeding the amount of €3,000, the trial is performed on the basis of oral witness testimony and every witness is ordinarily examined viva voce.
Other than the aforesaid fast-track procedure, the main expedited trial procedure available is the “summary judgment” procedure, which enables the plaintiff to obtain summary judgment without full trial if he can prove his claim clearly, if the conditions prescribed under Order 18 of the CPR are satisfied and if the defendant is unable to set up a bona fide defence or raise an issue against the claim which ought to be tried. 
 
1.4 What is your jurisdiction’s local judiciary’s approach to exclusive jurisdiction clauses?
The approach of the Cyprus Courts to exclusive jurisdiction clauses is that where there is a valid agreement established with a jurisdiction clause, then such clause shall be applicable in all cases, except where the plaintiff proves that there are good, serious and substantial reasons to evade it.
 
1.5 What are the costs of civil court proceedings in your jurisdiction? Who bears these costs?  Are there any rules on costs budgeting?
Initial costs of civil court proceedings are prescribed on the basis of the scale of the action and are paid upon the filing of the action.  Further to the initial costs, the costs of civil Court proceedings mainly include the costs for the preparation and filing of the legal documents, the costs of appearances before the Court and hearings, the costs of witnesses and the costs for the preparation of letters before and during the proceedings.  The Court will decide at the end of each case/civil claim who should pay the costs, but as a general rule, the losing party will be ordered to pay all the costs.
 
1.6 Are there any particular rules about funding litigation in your jurisdiction? Are contingency fee/conditional fee arrangements permissible?
Civil litigation is privately funded by the parties to the proceedings, and as a general rule the losing party will be ordered to pay all the legal costs.  However, there are instances where a party who cannot afford to pay the litigation costs may request the provision of legal aid from the state pursuant to the provisions of the Legal Aid Law (Law No. 165(I)/2002).
Contingency fee/conditional fee arrangements are not permissible in Cyprus since they are in conflict with the provisions of the Advocates’ Code of Conduct.
 
1.7 Are there any constraints to assigning a claim or cause of action in your jurisdiction? Is it permissible for a non-party to litigation proceedings to finance those proceedings?
Despite the fact that the legality of an assignment of a claim or cause of action has not yet been examined by the Cypriot courts, such assignment is not permissible in Cyprus, since it will offend the equitable principle against champerty.  Therefore, non-party funding is not available in Cyprus merely on the basis of the application of the aforementioned principle.
 
1.8 Can a party obtain security for/a guarantee over its legal costs?
The issue of a decree granting security for costs is regulated by Order 60 of the CPR.  Security for costs is only available against a plaintiff ordinarily resident out of Cyprus or out of any other Member State of the European Union.  When a security for costs order is issued against the plaintiff, he shall pay such security in Court or deposit the same in the form of a bank guarantee by any bank that carries out business in Cyprus, to the satisfaction of the Registrar of Court.  Normally the amount of security that can be ordered is the amount of costs expected to be incurred in defending the action.

2 Before Commencing Proceedings
 
2.1 Is there any particular formality with which you must comply before you initiate proceedings?
No pre-action steps are required before the initiation of a lawsuit except in certain special proceedings, such as winding-up proceedings or probate actions where the CPR provide for specific steps and procedures that must be followed before the initiation of the main proceedings.
 
2.2 What limitation periods apply to different classes of claim for the bringing of proceedings before your civil courts? How are they calculated? Are time limits treated as a substantive or procedural law issue?
In Cyprus, there are certain time limits for the filing of civil and commercial claims.  The Limitation of Actionable Rights Law of 2012 (Law No. 66(I)/2012) regulates the applicable limitation period and time starts to run on the day of completion of the cause of action.  There are different limitation periods depending on the nature of the action but, as a general limitation, no civil claim can be filed after the passing of 10 years.  The Law introduces different limitation periods for specific actionable rights.  For instance, the general limitation period for civil wrongs and for common contract claims is six years, at the expiration of which the right is time-barred.
Time limits are treated under Cyprus law as a substantive law issue rather than as a procedural one, and give the defendant a right to preliminary object by requesting the dismissal of the action against him if the claim has not been filed within the specified time limit.
 
3 Commencing Proceedings

3.1 How are civil proceedings commenced (issued and served) in your jurisdiction? What various means of service are there? What is the deemed date of service? How is service effected outside your jurisdiction? Is there a preferred method of service of foreign proceedings in your jurisdiction?

An action is commenced when a writ of summons has been filed with the competent district Court’s registry.  According to the CPR, a writ of summons could be either specially endorsed (Order 2, Rule 6) or generally endorsed (Order 2, Rule 1).
A writ of summons is issued when it is sealed by the Court and its sealing marks the beginning of the period of its validity for service purposes.  A writ of summons remains in force for 12 months from the day of its issue, and if not served within this period, the plaintiff must apply to the Court for its renewal. 

Service of the writ of summons to each defendant included in a writ is the responsibility of the plaintiff, who should serve them with an official copy of the writ in person through a private bailiff.  If the defendant is not found at his house or at his place of employment, the service shall be deemed to be effected if the copy is left:
i. with any member of his family aged apparently 16 years or over in his town or village;
ii. with any person apparently of such age and in charge of the place of his employment; or
iii. with his master in the case of a servant living with his master.
 
Service of the writ upon a company must take place at its registered office address by leaving such a copy at its registered office or by serving it upon one of the members of its board of directors.

If all of the above have been exhausted without succeeding in effecting service of the writ upon the defendant, then the plaintiff may apply to the Court for leave for substituted service (i.e. by post, courier, fax, email, etc.) by means that will bring the pending proceedings to the attention of the defendant.

As far as foreign defendants are concerned, leave of the Court to serve the writ of summons abroad is a prerequisite.  The method of service upon foreign defendants depends on the country where the plaintiff intends to serve such a defendant and is governed by the relevant EU regulation, bilateral treaties and international conventions to which Cyprus is a party.  Foreign proceedings in Cyprus may be served in the manner that is permitted by the country where the proceedings are instituted.
 
3.2 Are any pre-action interim remedies available in your jurisdiction? How do you apply for them? What are the main criteria for obtaining these?
Generally speaking, pre-action interim remedies are not available in Cyprus as it is not possible to obtain an interim remedy without first having to instigate substantive proceedings.  However, one pre-action interim remedy available in our legal system is the discovery order, the so-called ‘Norwich Pharmacal’ order, granted in order to assist the plaintiff in collecting information and documents with a view to identifying the wrongdoers and putting the puzzle together, enabling the filing of a legal suit.
 
3.3  What are the main elements of the claimant’s pleadings?
The main claimant’s pleading is the statement of claim which shall contain, and contain only, a statement in a summary form of the material facts on which the party pleading relies for his claim, but not the evidence by which they are to be proven.  Every statement of claim shall state specifically the relief which the plaintiff claims and shall be signed by the advocate, or by the party, if he sues in person.
 
3.4 Can the pleadings be amended? If so, are there any restrictions?
Pleadings can be amended pursuant to Order 25 of the CPR.  Order 25 has been recently amended and it now has a stricter wording that aims at the speeding up of the court proceedings whilst avoiding extensive amendments that used to be allowed at any stage of the proceedings.  According to the new Order 25, a party to the claim may proceed to the amendment of his pleadings, either with or without the leave of the Court, depending on the stage of the case, as follows:
• The plaintiff may amend the writ of summons without the leave of the Court anytime after the filing of the writ of summons and before the service of the latter.
• After the exchange of the pleadings and before the issuance of the summons for directions by the plaintiff in accordance to Order 30 of the CPR, any amendment is allowed without the leave of the Court.  If this is the case, the other party to the claim has 15 days after the date of filing of the amended pleading to file his/her own amended pleading, if necessary.
• After the issuance of the summons for directions as requested by Order 30 of the CPR, no amendment is allowed unless such requested amendment relates to (i) a bona fide mistake regarding the drafting of the pleading, or (ii) new facts which were not in existence at the time when instructions were received or at the time of the filing of the writ of summons or of any other pleading.
 
3.5 Can the pleadings be withdrawn?  If so, at what stage and are there any consequences?
There is no explicit provision in our CPR regarding withdrawal of pleadings in general.  However, under Order 15 of the CPR, the plaintiff may at any time before the receipt of the defendant’s pleaded defence, or after the receipt of the defendant’s pleaded defence before taking any other proceeding in the action (save any interlocutory application), by notice in writing wholly discontinue his action or withdraw any part or parts of his alleged cause of complaint, and thereupon he shall pay such defendant’s costs of the action.
At any other stage of the proceedings, the plaintiff needs to obtain the leave of the Court in order to withdraw his action and again he shall pay such defendant’s costs of the action.  The plaintiff must be cautious when asking the Court for leave to withdraw his claim since it is important to state whether he withdraws the claim unreservedly or “without prejudice”.  In the former occasion, a claim which is withdrawn unreservedly is dismissed permanently, and the doctrine of “res judicata” applies.  In the case of “without prejudice”, the plaintiff reserves his right to file a claim against the same defendant afresh if he so desires, without being estopped by operation of the aforesaid doctrine.
 
4 Defending a Claim

4.1 What are the main elements of a statement of defence? Can the defendant bring a counterclaim(s) or defence of set-off?
As we have seen above, every pleading shall contain, and contain only, a statement in a summary form of the material facts on which the party pleading relies for his claim or defence.  No defence shall be pleaded in abatement.
A defendant may bring a counterclaim, but he shall do so by stating specifically in his defence that he does so by way of a counterclaim.  In Cyprus, the defence of set-off is not available.   
 
4.2 What is the time limit within which the statement of defence has to be served?
Where a defendant has entered an appearance, he shall file and deliver his defence within 14 days from the time he filed his appearance in the case of a specially endorsed writ of summons, and within 14 days from the filing of the statement of claim in the case of a generally endorsed writ.

4.3 Is there a mechanism in your civil justice system whereby a defendant can pass on or share liability by bringing an action against a third party?
The mechanism whereby a defendant can pass on or share liability by bringing an action against a third party can be found in Order 10 of the CPR, under which the Court may give leave to the defendant to issue and serve a “third party notice” or a notice of claim against a co-defendant if he is able to claim that: (1) he is entitled to contribution or indemnity; (2) he is entitled to any relief or remedy relating to or connected with the original subject matter of the action; or (3) that any question or issue relating to or connected with the said subject matter is substantially the same as some question or issue arising between the plaintiff and the defendant, and should properly be determined not only as between the plaintiff and the defendant but as between the plaintiff, the defendant and a third party, or between any or either of them.
 
4.4 What happens if the defendant does not defend the claim?
If the defendant does not defend the claim by not entering his appearance in the Registry out of which the writ of summons was issued within 10 days from the day of service of the writ, then the plaintiff is entitled to apply ex parte for judgment in default and a judgment will eventually be issued in his favour, given the plaintiff adequately proves his claim through an affidavit.
 
4.5 Can the defendant dispute the court’s jurisdiction?
Yes.  A defendant in Cyprus proceedings can dispute the Court’s jurisdiction if the Court lacks jurisdiction to hear the case and/or when there is a more appropriate forum to hear the proceedings.
 
5 Joinder & Consolidation

5.1 Is there a mechanism in your civil justice system whereby a third party can be joined into ongoing proceedings in appropriate circumstances? If so, what are those circumstances?
Yes, there is. Please refer to question 4.3 above.
 
5.2 Does your civil justice system allow for the consolidation of two sets of proceedings in appropriate circumstances? If so, what are those circumstances?
Order 14 of the CPR provides that when two or more actions are pending in the same court, whether by the same or different plaintiffs against the same or different defendants, and the claims of these actions involve such a common question of law or fact which renders it desirable that the actions should be consolidated, the Court has the discretion to order the consolidation of these actions.
 
5.3 Do you have split trials/bifurcation of proceedings?
Cyprus Courts have the discretionary power to order split trials and consequential amendments to be made when, in the same action, several causes of action cannot be conveniently tried or disposed of together.
 
6 Duties & Powers of the Courts
 
6.1 Is there any particular case allocation system before the civil courts in your jurisdiction? How are cases allocated?
The allocation system before the civil courts in Cyprus depends on the scale of each claim.  Each District Court Judge may hear and adjudicate upon cases where the claimed amount is up to €100,000; each Senior Judge upon cases where the claimed amount is up to €500,000; and each President Judge upon cases where the claimed amount is over €500,000.
 
6.2 Do the courts in your jurisdiction have any particular case management powers? What interim applications can the parties make? What are the cost consequences?

Under Order 30 of the CPR, the parties may seek directions and case management by the Court on the following preliminary matters:
• further and better particulars of the pleadings;
• admission of facts;
• disclosure and inspection of documents;
• joinder of actions;
• security for costs; and
• any other procedural issue that must be dealt with before a hearing date is fixed.
 
The Court has a general discretion to hear interim applications and grant interim remedies.  Normally, costs are in the course except in particular instances where the costs are awarded to one of the parties, usually paid after the final determination of the action.
 
6.3 What sanctions are the courts in your jurisdiction empowered to impose on a party that disobeys the court’s orders or directions?
The Courts in Cyprus have the power to impose sanctions on a party that disobeys the Court’s orders or directions, and these sanctions vary according to the order or directions which a party disobeys.  The Court may award the costs of a particular procedure against such a party or, in particular instances, it may dismiss an action if it is the plaintiff who disobeyed, or strike out the defence if it is the defendant.  Furthermore, a breach of a Court order may amount to civil contempt or, as it is sometimes called, “contempt in procedure”.
 
6.4 Do the courts in your jurisdiction have the power to strike out part of a statement of case or dismiss a case entirely? If so, at what stage and in what circumstances?
Under the CPR, a party to an action brought in Cyprus may apply by summons to the Court to strike out any pleading which:
  •  discloses no reasonable cause of action or defence;
  •  is scandalous, frivolous or vexatious; or
  •  constitutes an abuse of process.
Further grounds for striking out a pleading are when the Court lacks jurisdiction to entertain a claim or when there has been a failure to comply with a direction or order of the Court. 

6.5 Can the civil courts in your jurisdiction enter summary judgment?
According to Order 18 Rule 1(a) of the CPR: “where the defendant appears to a writ of summons specially indorsed under Order 2, Rule 6, the plaintiff may on affidavit made by himself, or by any other person who can swear positively to the facts, verifying the cause of action, and the amount claimed (if any), and stating that in his belief there is no defence to the action, apply for judgment for the amount so indorsed, together with interest (if any), or for the recovery of the land (with or without rent), or for the delivering up of a specific chattel, as the case may be, and costs.  And judgment for the plaintiff may be given thereupon, unless the defendant shall satisfy the Court that he has a good defence to the action on the merits, or disclose such facts as may be deemed sufficient to entitle him to defend.”
 
6.6 Do the courts in your jurisdiction have any powers to discontinue or stay the proceedings? If so, in what circumstances?
In general, the Courts have the power to stay or discontinue the proceedings in the following circumstances:
  • when a foreign court has jurisdiction over the claim under an exclusive jurisdiction clause in an agreement;
  • when there is an arbitration clause in the agreement;
  • when the claim is considered to be a cross-action; or
  • when the same or related proceedings are pending elsewhere.
7 Disclosure
 
7.1 What are the basic rules of disclosure in civil proceedings in your jurisdiction? Is it possible to obtain disclosure pre-action? Are there any classes of documents that do not require disclosure? Are there any special rules concerning the disclosure of electronic documents or acceptable practices for conducting e-disclosure, such as predictive coding?
Order 28 of the CPR regulates discovery under oath and inspection of documents.  Parties effect disclosure by listing in a sworn affidavit the documents which are in their possession, custody or control, served on every party to the litigation.
Prior to the instigation of an action, disclosure is only available against non-parties who are “mixed up in the tortious acts of others so as to facilitate their wrongdoing” through the issue of the so-called “Norwich Pharmacal” order.
 
7.2 What are the rules on privilege in civil proceedings in your jurisdiction?
In civil proceedings, the main matters protected from disclosure or production on the grounds of privilege are:
• professional confidences;
• without prejudice communications; and
• incriminating questions.
 
7.3 What are the rules in your jurisdiction with respect to disclosure by third parties?
In Cyprus, as a general rule a third party cannot be compelled to make disclosure.  However, if relevant material or information is held by a third party then a subpoena duces tecum may be issued by the Court compelling the third party to produce documents during trial.  Another way to compel a third party to disclose information or documents is through the issue of a “Norwich Pharmacal” order, as we have seen in question 7.1 above.   
 
7.4 What is the court’s role in disclosure in civil proceedings in your jurisdiction?
The disclosure process is always supervised by the Court and in cases where a party fails to make discovery of documents, he shall not afterwards be at liberty to submit any document that he failed to disclose, unless the Court is satisfied that he had a satisfactory excuse for so failing.

7.5 Are there any restrictions on the use of documents obtained by disclosure in your jurisdiction?
A party which receives documents disclosed under Order 28 of the CPR may use those documents only for purposes connected with the proper conduct of the present litigation.

8 Evidence

8.1 What are the basic rules of evidence in your jurisdiction?
The basic rules of evidence in Cyprus are codified in Evidence Law, Cap. 9.  In civil cases, the plaintiff bears the burden of proof on the balance of probabilities.

8.2 What types of evidence are admissible, and which ones are not? What about expert evidence in particular?
All evidence available at a party’s disposal is admissible provided that it is relevant to the litigious facts and it is the best available evidence at hand.  Evidence that is irrelevant or breaches privilege, or was obtained illegally or is in violation of a Constitutional provision, shall not be admissible.  Expert evidence is admissible in Cyprus.
 
8.3 Are there any particular rules regarding the calling of witnesses of fact, and the making of witness statements or depositions?
In actions where the claim exceeds €3,000, evidence by a witness of fact may be given through oral witness testimony and his examination-in-chief may take place via a written statement; whereas in actions where the claim is under €3,000, the hearing takes place via the exchange of written testimony in the form of sworn affidavits accompanied by all material evidence.
 
8.4 Are there any particular rules regarding instructing expert witnesses, preparing expert reports and giving expert evidence in court? Are there any particular rules regarding concurrent expert evidence? Does the expert owe his/her duties to the client or to the court? 
Each party is free to appoint an expert witness to testify before the Court in support of the claim or defence if there is an issue in dispute which calls for scientific, technical or professional opinion.  The other party may call an expert witness themselves to rebut the other party’s expert report.  The expert owes its duty to the Court. 
 
9 Judgments & Orders
 
9.1 What different types of judgments and orders are the civil courts in your jurisdiction empowered to issue and in what circumstances?
The civil courts in Cyprus are empowered to issue monetary or declaratory judgments, prohibitory or mandatory orders and any other relief or remedy available in law or equity. 
 
9.2 What powers do your local courts have to make rulings on damages/interests/costs of the litigation?
Civil courts are empowered to award damages, interests and costs of the litigation.
 
9.3 How can a domestic/foreign judgment be recognised and enforced?
A domestic judgment becomes automatically enforceable upon its issue unless the court specifically stays its enforceability for a particular period of time.  The judgment creditor has several options under Civil Procedure Law, Cap. 6, as to how to proceed with the execution of the judgment against the judgment debtor.

On the other hand, foreign judgments need to be registered and recognised in order for the judgment creditor to be able to enforce his judgment in Cyprus.  For judgments given in a Member State, EU Regulation No. 1215/2012 (recast EC Regulation No. 44/2001) applies, whereas for non-EU judgments, Cyprus is bound by various bilateral treaties and multilateral conventions relating to their recognition and enforcement.

9.4 What are the rules of appeal against a judgment of a civil court of your jurisdiction?
Cyprus has a two-tier court system: the First Instance Courts; and the Supreme Court, which is the appellate court.  According to Article 25 of the Courts of Justice Law, an appeal before the Supreme Court may be brought in relation to: (1) any final judgment or order of a court exercising civil jurisdiction; (2) any order of a prohibitory or imperative nature or for the appointment of a receiver; and (3) interlocutory judgments having a determinative effect on the rights of the parties.  Moreover, Order 35 rule 2 of the CPR provides that no appeal from any interlocutory order shall be brought after the expiration of 14 days, and no other appeal shall be brought after the expiration of six weeks.
 
10 Settlement

10.1 Are there any formal mechanisms in your jurisdiction by which parties are encouraged to settle claims or which facilitate the settlement process?
In Cyprus, there is no formal mechanism for the settlement of claims.  An action can be settled at will and no court approval is required in order to do so.
 
II. ALTERNATIVE DISPUTE RESOLUTION

1 General

1.1 What methods of alternative dispute resolution are available and frequently used in your jurisdiction? Arbitration/Mediation/Expert Determination/Tribunals (or other specialist courts)/Ombudsman? (Please provide a brief overview of each available method.)
The most common means of dispute resolution in Cyprus is litigation.  Recourse to ADR is not compulsory, so the parties are free to choose whether to refer their dispute to arbitration or mediation for settlement, with the former being more commonly used.
 
1.2 What are the laws or rules governing the different methods of alternative dispute resolution?
The law governing mediation is the Law on Certain Aspects of Mediation in Civil Matters of 2012, whereas arbitration is governed by both Arbitration Law, Cap. 4 (for domestic arbitral proceedings) and the Law on International Commercial Arbitration of 1987.
 
1.3 Are there any areas of law in your jurisdiction that cannot use Arbitration/Mediation/Expert Determination/Tribunals/Ombudsman as a means of alternative dispute resolution?
In Cyprus any matter concerning criminal law, family law or which may have public policy implications is considered to be non-arbitrable.
 
1.4 Can local courts provide any assistance to parties that wish to invoke the available methods of alternative dispute resolution? For example, will a court – pre or post the constitution of an arbitral tribunal – issue interim or provisional measures of protection (i.e. holding orders pending the final outcome) in support of arbitration proceedings, force parties to arbitrate when they have so agreed, or order parties to mediate or seek expert determination? Is there anything that is particular to your jurisdiction in this context?
Cyprus Courts tend to stay or even dismiss court proceedings in cases where there is a valid arbitration agreement between the parties. Local Courts have jurisdiction to issue interim injunctions in aid of pending or contemplated local or foreign arbitration proceedings. Section 9 of the Law on International Commercial Arbitration provides the legal basis upon which our Courts can grant interim orders in aid of international commercial arbitration and this sort of assistance is frequently sought in Cyprus by parties involved in international arbitration proceedings abroad.

1.5 How binding are the available methods of alternative dispute resolution in nature? For example, are there any rights of appeal from arbitration awards and expert determination decisions, are there any sanctions for refusing to mediate, and do settlement agreements reached at mediation need to be sanctioned by the court? Is there anything that is particular to your jurisdiction in this context?
A domestic arbitration award may be set aside pursuant to Section 20 of the Arbitration Law, Cap. 4, whereas an international commercial arbitration award cannot be challenged on the merits per se.  However, an application can be made to the Court to set aside such an award within three months of the notification/communication of the award on the grounds provided by Section 34 of the Law on International Commercial Arbitration.
 
2 Alternative Dispute Resolution Institutions

2.1 What are the major alternative dispute resolution institutions in your jurisdiction? 
In Cyprus, a number of institutions offer ADR services such as the Cyprus Chamber of Commerce and Industry (CCCI), the Cyprus Eurasia Dispute Resolution and Arbitration Centre (CEDRAC) and the Cyprus Arbitration and Mediation Centre (CAMC).