Arbitration is a well recognized mode for resolving disputes arising out of international commercial transactions. An arbitration award is a determination on the merits by an arbitral tribunal in an arbitration, and is analogous to a judgment in a court of law. Once a dispute between parties is settled, the winning party needs to collect the award. Unless the assets of the losing party are located in the country where the award was rendered, the winning party needs to obtain a court judgment in the jurisdiction where the other party resides or where its assets are located. Unless there is a treaty on recognition and enforcement of foreign arbitral awards between the country where the award is rendered and the country where the winning party seeks to collect, the winning party will be unable to use the court judgment to collect. However, one of the problems faced in such arbitrations related to recognition and enforcement of an arbitral award made in one country by the courts of other countries. This difficulty has been sought to be removed through various international conventions. The New York Convention is one of the key instruments in international arbitration which applies to the recognition and enforcement of foreign arbitral awards. However, the world of international arbitration has changed since the creation of the Convention so it needs a complementary to the Convention which deals with the issues that have arisen in the practice of international arbitration during the last 50 years.

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