ILLEGALITY IN INTERNATIONAL ARBITRATION
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his paper explores how international arbitration is affected by questions of illegality, fraud and corruption or public policy concerning such issues. The primary question is, to what extent will a tribunal’s decision on illegality be subject to review by a supervisory court or enforcement court? The discussion is based on the UNCITRAL Model Law on International Commercial Arbitration and the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. The article uses illustrations from Singapore and England to illustrate how courts have approached these issues.
Abstract
his paper explores how international arbitration is affected by questions of illegality, fraud and corruption or public policy concerning such issues. The primary question is, to what extent will a tribunal’s decision on illegality be subject to review by a supervisory court or enforcement court? The discussion is based on the UNCITRAL Model Law on International Commercial Arbitration and the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. The article uses illustrations from Singapore and England to illustrate how courts have approached these issues.