ABSTRACT: The recognition and enforcement of annulled arbitral awards has long been the subject of debate. In the spirit of a "delocalized" approach to arbitration, the courts of several countries have recognized or enforced such awards. This article shows that the New York Convention provides for this possibility, analyzes the scope of the Convention and its basic principles in this regard, and undertakes an investigation of relevant French and American caselaw and of approaches adopted in other countries.
Revista Brasileira de Arbitragem