Arbitration Law Monthly
Enforcement of foreign awards: public policy
In Alexander Brothers Ltd (Hong Kong SAR) v Alstom Transport SA [2020] EWHC 814 (Comm) the defendants sought procedural orders for the admission of evidence of French law to assist them in their argument that enforcement of a Swiss award under the New York Convention would be contrary to public policy under section 103(3) of the Arbitration Act 1996.
The facts