The appellant appealed a decision recognizing and enforcing a foreign arbitral award from the Dubai International Financial Centre.
The appellant argued the application judge erred under Article V 1(d) of the Convention by considering Dubai law to determine the applicable arbitral procedure, rather than strictly applying the rules specified in the parties' agreement.
The Court of Appeal dismissed the appeal, finding the application judge correctly interpreted the agreement as incorporating amended rules and properly considered Dubai law to determine what those amended rules were.
The court also rejected arguments that the procedure was unfair or contrary to public policy.
