Abstract

The finality of commercial arbitration awards is a fundamental principle that ensures the efficiency, predictability and autonomy of international dispute resolution. However, exceptions to finality-particularly those based on public policy, excessive authority, and procedural fairness-have led to increased judicial intervention. This study provides a comparative analysis of the legal frameworks and judicial practices in the United States, the United Kingdom, and China, exploring how courts interpret and apply these exceptions. While judicial oversight mechanisms, narrowly defined, enhance the legitimacy of arbitration by preserving due process and legal integrity, excessive intervention may erode its functional benefits. Through doctrinal and case law analysis, this study examines how jurisdictions balance finality with judicial control and proposes reforms to align national arbitration laws with international standards, preserving both arbitral autonomy and systemic accountability.