The Supreme Court of Pakistan held that an award made in a Convention country based on an arbitration agreement governed by the law of Pakistan is a foreign award for the purposes of the Recognition and Enforcement of Arbitration Agreement and Foreign Award Act 2011. The Court also found that the 2011 Act applies retrospectively to awards made in arbitration proceedings initiated before the Act came into force, and stressed the proenforcement bias of the Convention, particularly in respect of the 1927 Geneva Convention.