Paul Hobeck and Christian Stubbe explained that internationally operating companies fear a “surprising interpretation of the term public policy” when it comes to the recognition and enforcement of…
The UK Supreme Court released its judgment today in a much-written about dispute pitting a Saudi company against the Government of Pakistan. In the judgment, the Court declined to enforce a 2006 ICC…
The European Convention on International Commercial Arbitration 1961 (ECICA) is a multilateral treaty regulating certain aspects of international arbitral proceedings. Some of its provisions cover…
Can arbitrators be called to give testimony on the arbitral procedure before the court in charge of annulment or enforcement actions? Courts in England and Norway had to tackle this issue and have…
The discussion on the position of arbitration in the Brussels Jurisdiction and Enforcement Regulation (Regulation 44/ 2001) has now reached the Committee on Legal Affairs of the European Parliament…
When discussing public policy, English lawyers like to quote the famous comment of an English judge in the early 19th century that "public policy is a very unruly horse, and once you get astride it…
An interesting issue regarding the enforceability of foreign arbitral awards, in relation to the provisions of the New York Convention of 1958 and its alleged conflict with domestic Greek Civil Code…
Under the Russian legal system, the last resort a party has with respect to challanging a court decision is to apply to the Constitutional Court of the Russian Federation with a claim to review the…
I am grateful to Professor Hess for his comments on my 3 March 2010 blog. It greatly contributes to advancing the debate. However, it also perfectly illustrates the difficulties of a proposition –…
