On 20 August 2021, the Gauteng Local Division of the High Court of South Africa, in Johannesburg, granted enforcement of an award rendered in South Africa in an international arbitration between a South African and a Croatian party. The defendant resisted enforcement on the ground that it had commenced a separate action in the High Court, seeking the same relief it had sought in its counterclaim in the arbitration, which had been denied by the sole arbitrator. The High Court rejected this defense, in light of the pro-enforcement bias of the UNCITRAL Model Law, which was adopted into South African law through the 2017 International Arbitration Act, and of the New York Convention.