GERMANY 38
Germany 38. Bundesgerichtshof, 18 January 1990
The court discusses the determination and relevance of the place where the award was made (in a foreign State or another contracting State.
The court discusses the overall scheme and/or pro-enforcement bias of the Convention.
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.
Public policy: The court discusses the consequences of the lack of reasons in the award on its recognition and enforcement.
Public policy: The court discusses the effect of other alleged violations of public policy on the recognition and enforcement of an arbitral award, such as contradictory reasons, manifest disregard of the law (US), etc.
More-favorable right provision: The court discusses examples of domestic laws of countries where enforcement of foreign awards is more favorable.