Parrish applied for recognition and enforcement of an award rendered by the Appeals Committee of the National Grain and Feed Association (NGFA) in the United States. TSM resisted the application, arguing that there was no agreement in writing between the parties, because they had negotiated by text and email messages; that Parrish failed to meet the procedural requirements for recognition and enforcement by not filing a certified or original copy of the arbitration agreement; and that the NGFA Appeals Committee exceeded the scope of the parties’ submission to arbitration, thereby depriving TSM of the opportunity to present its case on the matter which formed the basis of the award. The Court concluded that it should adjourn the application in order to permit Parrish to file certified copies of the award and the arbitration agreement. The Court was however satisfied that, but for the absence of the certified copies, the application should be allowed. Before reaching its decision, the Court set out the framework for the recognition and enforcement of foreign awards, as established by Saskatchewan and Canadian legislation, the UNCITRAL Model Law and the New York Convention, noting that this framework is generally recognized to have been “an unqualified success”.