Lost the Battle, But Not the War: Annulment and Resisting Arbitral Awards in the Netherlands - Arbitration: The International Journal of Arbitration, Mediation and Dispute Management View Lost the Battle, But Not the War: Annulment and Resisting Arbitral Awards in the Netherlands by - Arbitration: The International Journal of Arbitration, Mediation and Dispute Management Lost the Battle, But Not the War: Annulment and Resisting Arbitral Awards in the Netherlands 91 4

This article explores when Dutch courts may set aside or refuse to recognize arbitral awards, whether issued in the Netherlands or abroad. It sets out the relevant legal framework under the Dutch Code of Civil Procedure (DCCP) and the New York Convention, highlighting the distinction between domestic and foreign awards. Drawing on more than 500 court decisions, the analysis focuses on the grounds most often accepted in practice. These include breaches of public policy – especially where the right to be heard was denied – the absence of a valid arbitration agreement, failure to provide adequate reasoning, and situations where the tribunal exceeded its authority. While Dutch courts have the power to intervene on these grounds, they exercise that power with caution. The data show that set-aside or refusal has been granted in only about 20% of cases. This suggests that although losing parties in arbitration do have procedural options to resist enforcement, the bar remains high. Dutch courts continue to favour enforcement in principle and intervene only where there is a clear and serious defect. The article offers a practical and doctrinal look at how Dutch courts balance deference to arbitral autonomy with the protection of core procedural rights.

Arbitration: The International Journal of Arbitration, Mediation and Dispute Management