Enforcement of nullified foreign arbitral awards under the New York convention on recognition and enforcement of foreign arbitral awards 1958 : a critical study to the USA and France court decisions

Abstract

The main of this research is to examine the New York Arbitration Convention position with regard to the possibility of the enforcement of foreign arbitral awards which have been nullified or set aside by the national courts of the seat of arbitration.

The paper examines the interpretation of the relevant provisions of the convention in light of the court decisions in both possibility, and to discuss also the unpleasant consequences of that possibility to the international public order and international comity.