Thomas Clay elaborates on the contributions of French case law to the promotion and development of the New York Convention. He demonstrates that French court decisions regarding the enforcement of Convention awards that had been annulled at the place where they had been rendered (Hilmarton, Putrabali) are at the vanguard of a truly international conception of arbitration. French court decisions have thus been instrumental to the construction of Article VII of the Convention.
Erratum: Due to a technical error during the editorial process, the footnotes for this article were missing in the published version. The article was re-published in its entirety in the March 2009 issue of the ASA Bulletin (Volume 27, Number 1).ASA Bulletin