International arbitration is replacing transnational litigation as the dispute resolution mechanism of choice for international commercial contracts, particularly in the areas of energy, oil and gas. This is largely down to the 1958 New York Convention on Arbitral Awards, which obliges courts of contracting states to honour the agreement and enforce awards. However, enforcement is often inconsistent across signatory states, partly because of the public policy defence. And with increasing economic uncertainty in developing countries, this already controversial defence may just attract more attention.