The Court granted exequatur of an ICC award rendered in Burkina Faso, which had been set aside at the seat, explaining that the annulment had no consequence on exequatur, because international awards are not subject to any state legal system and their validity must be examined solely under the rules applicable in the enforcement country – here, France. Applying the French Code of Civil Procedure, the Court dismissed Benin’s claim that the arbitral tribunal had lacked jurisdiction because the parties’ contract had been previously annulled by a Benin court. The Court referred to the substantive rule of international arbitration that an arbitration agreement is juridically independent from the main contract. Here, the validity of the arbitration clause itself was not disputed. As to the further argument that exequatur would be in violation of the international public policy principle of res judicata, the Court reasoned that in order for an award to be irreconcilable with a foreign court decision – in which case French international public policy may be affected – both decisions must be enforceable in France. In the present case, Benin had not requested exequatur of any of the Benin or Burkina Faso court decisions.