Introduction

Public policy is one of the most popular grounds commonly used by parties to international arbitration to resist enforcement of arbitral awards. Till today, it remains a highly debated, controversial and complex subject. This is because of the diverse approach taken by national courts in relation to the concept of public policy in international arbitration. Although over time, arbitration laws and practice have tried to align the concept of public policy so that parties may benefit from a universally accepted concept of public policy, the difference in attitude of national courts has ...