Part II Legal Framework: Courts, Statutes and Treaties, C The Effect of Annulment, 1 What is to be Done with Annulled Awards?

If an award rendered in Boston is set aside by a court in Massachusetts, should it (can it) be given effect against assets in Paris or London? Different courts take varying positions. Although the French have shown little difficulty in enforcing annulled awards, American and British courts tend to hesitate. The effect of annulled awards presents itself differently in an international context from a single-country context. If a judge in Boston vacates an award made in Massachusetts, the award normally becomes unenforceable against assets throughout the United...