A Siberian Contribution to English Law: Public Policy, Illegality and the Enforcement of International Arbitration Awards: Soinco S.A.C.I. v Novokuznetsk Aluminium Plant and Subsequent Cases
Article from: TDM 0 (2003), in International Commercial Arbitration
Abstract
Article V(2) of the New York Convention 1958 states: " enforcement of an arbitral award may also be refused if the competent authority in the country where - enforcement is sought finds that - enforcement of the award would be contrary to the public policy of that country." What does this mean in practice? How did a Siberian aluminium plant make a significant contribution to refinement of the English law of 'public policy' applicable in enforcement proceedings? The past five years have seen four cases (Soinco, Soleimany, Westacre and Hilmarton) in the English Courts which ...