The enforcement of annulled awards has been an extensively debated topic in international commercial arbitration. The drafting history of Article V of the New York Convention (NYC) indicates that discretion was granted to Member States to refuse enforcement of annulled awards. However, most jurisdictions have either adopted a territorial approach or an internationalist or delocalized approach when it comes to annulled awards. In this paper, we argue that there are many flaws in the delocalized approach adopted by various jurisdictions. The territorial approach is also not feasible due to differing standards of enforcement in different jurisdictions. We bring forth a more balanced approach to the enforcement of annulled awards, which borrows from the stance of William W. Park on this issue. We argue that annulment decisions should be seen as akin to decisions of foreign jurisdictions. Further, we argue that the public policy ground could be used to create sufficient grounds for refusal of enforcement when necessary.