Enforcement of Foreign Arbitral Awards and the Public Policy Exception

Bruno Zeller is Professor of Transnational Law at the University of Western Australia, Perth; Adjunct Professor at Murdoch University, Perth; Fellow of the Australian Institute for Commercial Arbitration, Panel of Arbitrators – MLAANZ; Visiting Professor at Humboldt University, Berlin and a Visiting Professor Stetson Law School, Florida.   Prof. Zeller is an international law consultant with Michael Bula Solicitors and specializes in transnational commercial law. He is the author of the seminal work – Four-Corners - The Methodology for Interpretation and Application of the UN Convention on Contracts for the International Sale of Goods (2003), amongst a host of research work in the form of books, chapters in edited collections and journals.  His research in the area of transnational commercial law and commercial arbitration is much cited. Gautam Mohanty- Gautam Mohanty is an Assistant Professor at Jindal GlobalLaw School(JGLS), O.P.Jindal Global University. He graduated from National Law University Odisha in the year 2015 and has a Master’s in International Business Law from Central European University in 2017. He is also an arbitration consultant and has experience advising domestic and international clients in commercial and dispute resolution matters. He has served as an Arbitration Tribunal Secretary to Hon’ble Justice Deepak Verma, Former Judge of Supreme Court of India in several arbitration matters. Further, he has published his work in several reputed journals and his areas of interest include international commercial arbitration, international investment law, private international law, Blockchain and the law. He is currently a doctoral student at Kozminski University, Warsaw, Poland.Sai Ramani Garimella- Sai Ramani Garimella teaches international commercial law and arbitration at South Asian University, an inter-governmental organizationof the South Asian Regional group, SAARC. She is also a Visiting Senior Research Associate at Research Center for Private International Law in Emerging Countries, University of Johannesburg, Johannesburg, South Africa. Her research interests include international arbitration, international commercial law, private international law, and theoretical constructs in international law. Her research on international arbitration has appeared, recently, in the Manchester Journal of International Economic Law, Pepperdine Dispute Resolution Journal, amongst others. She has co-edited a commemorative volume on the CISG, titled CONTRACTS FOR THE INTERNATIONAL SALE OF GOODS: A MULTIDISCIPLINARY PERSPECTIVE.  (A Commemorative Volume Celebrating 30 Years of The CISG (Sweet & Maxwell, 2019), contributing an essay on Article 42 - - Third Party IPR Claims in Transnational Commerce –Addressing the Indeterminacy.  She has been awarded the Isambard Kingdom Brunel fellowship by the University of Portsmouth in 2019. She has previously co-edited a collection of essays on Private International Law - South Asian State Practice for Springer (2017).

• Introduction to the book.- The Exceptions to the Enforcement of the Foreign Arbitral Awards within the New York Convention – Jurisprudence from State Practice.- UNCITRAL Model Law.- The Public Policy Exception to Enforcement – the Origins in Private Law.- State practice on the Delimitation and Interpretation – the Maximalist and Minimalist Approaches.- Public Policy – Need to Rein the Unruly Horse.- Conclusion.