CHILE 2024-2

Corte Suprema de Justicia de Chile, First Civil Chamber, 27 July 2023, ROL no. 133313-2022

(Ashlock Company Division of Vistan Corporation v. ... Read more

Corte Suprema de Justicia de Chile, First Civil Chamber, 27 July 2023, ROL no. 133313-2022

(Ashlock Company Division of Vistan Corporation v. Procesadora Rengo SpA)

27 - 07 - 2023

CHILE 2024-2

Yearbook Yearbook Commercial Arbitration, S. W. Schill (ed.), Vol. XLIX (2024)
Jurisdiction Chile
Summary

The Supreme Court granted leave to enforce a California award, finding that the respondent had been duly notified of the arbitration, the dispute was arbitrable, and exequatur would not violate Chilean public policy. Hence, there were no grounds for refusal under the New York Convention. The Court stressed at the outset that in the exequatur proceedings neither the merits of the awards nor defences to be raised at the stage of the award’s execution were discussed, the latter falling within the scope of the competence of the execution court.

Related topics
301

The court discusses the principle that the procedure for the enforcement of awards under the Convention is governed by the lex fori, as well as procedural issues (such as the competent enforcement court) not falling under the specific cases of ¶¶ 302-307.

Procedure for enforcement in general
500

The court discusses the overall scheme and/or pro-enforcement bias of the Convention.

Grounds for refusal of enforcement in general
502

The court discusses the principle that the merits of the award may not be reviewed and that the court may only carry out a limited review of the award to ascertain grounds for refusal.

No re-examination of the merits of the arbitral award
509

Due process: The court discusses what constitutes “proper notice” of the appointment of the arbitrators or of the arbitration proceedings.

"Proper notice"
518

Public policy: The court discusses the meaning of (international as compared to domestic) public policy, generally defined as the basic notions of morality and justice of the enforcement State.

Paragraph 2 - Distinction domestic-international public policy
519

Public policy: The court discusses cases in which the subject matter of the award was not arbitrable in the enforcement State on public policy grounds.

Ground a: Arbitrability
CHILE 2024-2