The enforcement of international arbitral awards in the Asia-Pacific region - a comparative study of recent cases

摘要

This article is a comparative study across the jurisdictions of Australia, Hong Kong and Singapore, examining the approach taken by each to the enforcement or setting aside of international arbitral awards. Focus is given particularly to the public policy ground for refusing to set aside a foreign award. Shared amongst the jurisdictions is a commitment to a pro-enforcement and non-interventionist judiciary. While the volume of international arbitration cases that are heard in each jurisdiction varies, the quality of jurisprudence and rigorous commitment to comity is upheld in all three.