Transnational Construction Arbitration

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Recognition and enforcement of domestic and foreign arbitral awards in the Middle East

Recognition and enforcement of domestic and foreign arbitral awards in the Middle East

Gordon Blanke


11.1 The present chapter discusses in some detail the practice and procedure of the enforcement of domestic and foreign commercial and investment arbitration awards in the construction sector in the Middle East. It should be noted from the outset that the enforcement of construction arbitration awards is no different from the enforcement of ordinary commercial (or investment) arbitration awards; there is hence no special regime that applies to the enforcement of arbitration awards dealing with construction disputes.1 In terms of geographical coverage, given prevailing constraints of space, the discussion will focus on some of the more prominent arbitration jurisdictions, such as the Gulf countries,2 Lebanon3 and Egypt.4,5 Occasional reference will be made to a jurisdiction

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outside this group of countries if it is felt necessary to do so in order to highlight developments that – albeit unique to it – are instructive for enforcement in the Middle East more generally, for example Jordan6 and Libya.7

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