Part II Legal Framework: Courts, Statutes and Treaties, C The Effect of Annulment, 2 Duty and Discretion in International Arbitration

After a long arbitration in New York, a Canadian company wins substantial damages against a British multinational, only to see a federal court vacate the award.1 Two grounds are given for vacatur: the arbitrator was biased and the arbitrator manifestly disregarded the applicable law. Not deterred by the vacatur, the winning claimant seeks to enforce the award against the defendant’s London bank accounts. What effect (if any) should a court in England give the American award? Should an English court ignore the arbitrator’s decision or the federal judge’s order?...