UNITED STATES 318
Yearbook
Yearbook Commercial Arbitration, A.J. van den Berg (ed.), Vol. XXV (2000)
Jurisdiction
United States
Original full text
Full text decision UNITED STATES 318
Summary
US 318. United States District Court, Southern District of New York, 25 June 1999
Related topics
102
Arbitral award not considered as domestic (paragraph 1)
The court discusses which awards are considered non-domestic even if rendered in the State of enforcement (international element, lex mercatoria).
500
Grounds for refusal of enforcement in general
The court discusses the overall scheme and/or pro-enforcement bias of the Convention.
518
Paragraph 2 - Distinction domestic-international public policy
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.
519
Ground a: Arbitrability
Public policy: The court discusses cases in which the subject matter of the award was not arbitrable in the enforcement State on public policy grounds.