Action to set aside

Action aimed at setting aside an award. Modern arbitration laws permit only limited review of an award by local courts in setting aside actions, and they do not permit any review of its merits. Under French law, the conditions for setting aside an award in international matters are the same as those for refusing its enforcement. Awards set aside in their country of origin (cf Seat of arbitration) cannot be enforced in that country and also may lose the benefit of enforcement under the New York Convention. However, some countries (such as France) allow an award set aside in its country of origin to be enforced in their territory if the conditions for doing so are fulfilled.