Enforcement of arbitration awards: New York Convention

In Carpatsky Petroleum Corporation v PJSC Ukrnafta [2020] EWHC 769 (Comm) the respondents sought to challenge an enforcement order in respect of an award made in Sweden. A number of defences were raised, including the absence of a binding agreement to arbitrate and serious procedural errors in the hearing. The defences raised questions relating to the law applicable to the arbitration clause and the effect of a decision by the curial court upholding the award and of decisions by other enforcing courts.

Carpatsky : the facts