The court discusses aspects relating to the implementation of the Convention in a Contracting State: the self-executing nature of the Convention v. the requirement of implementing legislation; the lack of implementing legislation; legislation that diverges from the text of the Convention or is defective under national law. Also, the domestic requirement that a State be included in an official list (“gazetted”) to ascertain reciprocity.

The court discusses issues specific to bills of lading and charterparties, such as whether the subsequent holder of the bill of lading is bound by the arbitration agreement therein and whether the arbitration clause in the charterparty is incorporated into the bill of lading.