This dissertation was written as part of the LLM in Transnational and European
Commercial law, Banking Law, Arbitration/Mediation at the International Hellenic
University.
Arbitration today is considered worldwide the prevailing choice for the resolution of
business disputes that entail a cross-border element. Parties’ autonomy as well as the
enforceability of the arbitral awards are among the central benefits of arbitration that
make it preferable. The adoption of the Convention on the Recognition and
Enforcement of Foreign Arbitral Awards (NY Convention) is a highlight in the history of
arbitration enhancing further its benefits at the post-award phase.
The Convention offers limited grounds to refuse recognition and enforcement , among
which is the public policy. National courts have the discretion to refuse recognition and
enforcement of an arbitral award if they assess that it is contrary to the fundamental
principles of the forum’s legal order. National jurisdictions have given a wide range of
interpretations to this notion.
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