SPAIN 112

Tribunal Superior de Justicia de Cataluña, Civil and Penal Chamber, First Section, 19 December 2023, Case No. 5/2023, Decision No. 176/2023

(METSCCO Heavy Steel industries Co Ltd v. Technologías ECONTROL S.L.)

19 - 12 - 2023

SPAIN 112

Yearbook Yearbook Commercial Arbitration, S. W. Schill (ed.), Vol. XL (2025)
Jurisdiction Spain
Summary

The Superior Court of Justice granted enforcement of an ICC award rendered in Switzerland. It found that there was no violation of due process and Spanish public policy because the arbitrator had denied the respondent the opportunity to present certain testimonial evidence; the arbitrators’ decisions regarding evidence were within their discretion and did not constitute a substantial procedural injustice or fundamental rights violation. The Court added that the testimonies at issue were immaterial, as they were inconsistent with documentary evidence

Related topics
502

The court discusses the principle that the merits of the award may not be reviewed and that the court may only carry out a limited review of the award to ascertain grounds for refusal.

No re-examination of the merits of the arbitral award
511

Due process: The court discusses various irregularities affecting due process, including letters not sent, names of arbitrators or experts not communicated, language of proceedings and communications, etc.

"Otherwise unable to present his case"
518

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.

Paragraph 2 - Distinction domestic-international public policy
523

Public policy: The court discusses alleged violations of a fundamental rule of due process in the arbitration on the recognition and enforcement of an arbitral award, including the failure to communicate the names of the arbitrators, the failure to send copies of reports or letters filed in the arbitration, etc.

Irregularities in the arbitral procedure (see also Art. V(1)(b))
SPAIN 112