Law stated as at 13 Nov 2009 • South Africa |
"an arbitral award
(a) made outside the Republic; or
(b) the enforcement of which is not permissible in terms of the Arbitration Act, 1965, but [it is] not in conflict with the provisions of this Act".
"The 'concerns of international comity, respect for capacities of foreign and transnational tribunals, and sensitivity to the need of the international commercial system for the predictability in the resolution of disputes' have given rise in other jurisdictions to the adoption of 'a standard which seeks to preserve the autonomy of the forum selected by the parties and to minimise judicial intervention when reviewing international commercial arbitration awards'."