Keywords: recognition, enforcement, state legislations, judicial process, grounds for challenge, foreign arbitral awards, arbitration law, foreign judgements, USA, United States, India, commercial arbitration
Recognition and enforcement of 'foreign arbitral awards': a comparative study
Arbitration does not necessarily end with the award. Within the differing domestic legal frameworks, the approaches adopted by individual jurisdiction like India and USA towards the grounds of opposition under the New York Convention (also provided in Geneva Convention, 1927, and UNCITRAL Model Law of 1985) cannot be the same. This even involves seminal questions relating to Limitation and Machinery of enforcement of Awards.