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, 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? Should the English court make its own investigation into the legitimacy of the vacatur

Arbitration · Arbitration clause · Business · Compulsory arbitration · Damages · Discretion · Duty · Federal court · Legitimacy · Multinational corporation · Order (exchange · Plaintiff · Political science · Supreme court · Corporate Law and Human Rights · Dispute Resolution and Class Actions · International Arbitration and Investment Law · Law