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  • Print publication year: 2020
  • Online publication date: February 2020

Article 36 - Grounds for Refusing Recognition or Enforcement


Article 36 of the Model Law concerns the recognition and enforcement of awards. The grounds for refusal are modelled after the New York Convention; as such, they are extremely limited and mainly focus on procedural irregularities. As already mentioned, article 36 was closely modelled on articles V and VI of the Convention. The Working Group did not want to deviate much from the Convention as it ‘worked well in practice’ and had given rise to few problems. Many States that had already joined the Convention went so far as to state that article 36 was unnecessary, as it would simply create duplication within their domestic legislation.