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The New York Convention is considered as the main pillar of the international arbitration and the most effective transnational legal instrument in international trade. But the most important challenge that the Convention is facing is a uniform application by the Member States. Article V of the Convention containing several grounds for refusal of recognition and enforcement of arbitral awards, could be deemed as an obstacle to achieve this goal. The most controversial ground is the public policy that affects the uniform application of the Convention and the predictability of the arbitration process. Then the lack of a definition for public policy has opened the door for different interpretations in different countries.The questions that the paper at hand deals with are the following: What are the consequences for the lack of a definition for the public policy ground in the New York Convention? Is it necessary to revise the New York Convention to address this issue?In order to answer these questions, the paper at hand will present some court decisions in order to elaborate the mentioned challenge and find an appropriate solution.

Public Policy as Ground for Refusal of International Arbitral Awards - A Comparison Between Different Judicial Practices