The Court reversed the first-instance decision and denied exequatur of a Bulgarian award, finding that the application was time-barred. A law firm purportedly acting for the award creditor had filed an application signed with the law firm’s seal within the mandatory three-year limit, but the application did not meet the validity requirements of Vietnamese law, which required that such applications be signed by the award creditor.
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The court discusses the applicable period of limitation for seeking enforcement of an award.