The finality of an award is a key feature and attraction of arbitration as a method of dispute resolution. When an award is annulled at the seat, however, enforcing courts in secondary jurisdictions…
The US Court of Appeals for the 2nd Circuit’s Thai-Lao Lignite (Thailand) v. Government of the Lao People’s Democratic Republic
The friction between a seat and an enforcement forum, i.e. between…
Under Article V(1)(e) of the 1958 United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“The New York Convention”), a court presented with an action to enforce an…
