Different Approaches in Enforcement of Arbitral Award Annulled at the Place of Arbitration

Abstract

This paper seeks to investigate whether the enforcement court should follow the decision of the court at the place of arbitration, or should it can reach a different decision. In doing so, section II briefly explains the text of the New York Convention. Section III identifies the national approaches on the enforcement of vacated award at the seat of arbitration, including that of France, and the United States. In section IV, the author analyzes the standards of arbitral award annulment set forth by the court of those jurisdictions. Finally yet importantly, the conclusion placed in section V.