engleski

Recognition and Enforcement of Foreign Annulled Awards - A Dilemma

In some countries, such as France, the United States of America and Austria, the courts occasionally render decisions on the enforcement of foreign annulled arbitral awards. The author analyses these debatable cases by taking into account comparative legal writing and both the relevant internal law and international conventions. In his opinion, as Art VII(1) of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards of 1958 refers to the European Convention on International Commercial Arbitration of 1961, if a Croatian court in a case on recognition and enforcement of a foreign annulled arbitral awards determines that Art. IX of the latter Convention should be applied, it should therefore enforce such an annulled award.

recognition and enforcement of foreign arbitral awards; private international law; international commercial arbitration

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