In this decision in the Devas saga, the Quebec Court of Appeal held that, although the Canadian State Immunity Act does not contain a specific arbitration exception, a state’s consenting to arbitration constitutes an express waiver of immunity from jurisdiction, by which the state submits to the adjudicative power of an arbitral tribunal and to “an international system of justice”. The Court also noted that India’s attempt to invoke immunity went against its obligations under Art. III of the NYC.