Enforcement of Foreign Arbitral Awards and the Public Policy Exception: Including an Analysis of South Asian State Practice

Bruno Zeller, Gautam Mohanty, Sai Ramani Garimella

Research output: Book/ReportBookpeer-review


The book presents arguments derived from primary sources related to international arbitration in South Asian jurisdictions, a list of the same is made available therein. The book is a research statement on the contemporary concerns within international commercial arbitration, especially related to enforcement of foreign arbitral awards. Importantly, the book through a unique methodology of interface, presents the gratuitous nature of Article 34 of the UNCITRAL Model Law when read with Article V of the New York Convention, especially the plea to the States within Article VII of the same Convention to ease the restrictions and the process of enforceability of foreign arbitral awards. The book also articulates another important and immediate need with regard to international arbitration – the delimitation of public policy exception to recognition and enforcement of foreign arbitral awards. It critiques the jurisprudence related to arbitration in jurisdictions spread across different geographic regions, thereby enabling the reader to gain an insight into their practices, apart from ensuring a comparative perspective. The book addresses the primary concern related to international arbitration – enforcement of foreign arbitral awards and the grounds for challenges articulated within the New York Convention and the UNCITRAL Model Law. It addresses these grounds, and articulates the necessity for carving the criteria for the application of public policy exception.
Original languageEnglish
Place of PublicationNetherlands
Number of pages183
ISBN (Electronic)978-981-16-2634-0
ISBN (Print)978-981-16-2633-3, 978-981-16-2636-4
Publication statusPublished - 2021


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