After the handover in 1997, the Supreme People's Court of Mainland China and the Department of Justice of Hong Kong concluded in 1999 a bilateral Arrangement to resolve the problem of enforcing arbitral awards. The Arrangement provides a unique implementation instrument. This paper examines a number of court rulings in Hong Kong and the Mainland and evaluates how the Arrangement has played out in reality. The author observes that both the Mainland and Hong Kong share certain basic intentions for applying the Arrangement, including exclusion of reviewing merits, a cautious attitude towards public policy, and relaxed procedural requirements. On the other hand, there are also some differences in judicial practice revealed in the cases. Some of these differences, such as the scope of the Arrangement's application and double enforcement, are derived from the ambiguity of the Arrangement itself and must be clarified. Others, such as the validity of the arbitration agreement and the difficulty in applying foreign law, arise from the different statutes and legal traditions and may be eliminated through the development of law and further legal assistance between the Mainland and Hong Kong.
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