Challenges to International Arbitral Awards The French Approach

Abstract

A dissatisfied party to an international arbitral process or decision may challenge such matters in the domestic courts of the country where the arbitration was held (the seat of arbitration) or where the award will be enforced.The approach taken by different countries to these challenges varies considerably. This article examines the approach taken under French law and procedure to challenges to international arbitral awards. This article considers the sources of French international arbitration law, when and how arbitral awards can be challenged under French law, and the grounds for challenges of arbitral awards under French law.