Tag: Reciprocity

Recognition of Russian Judgments, Arbitrazh Courts and the Requirement for Reciprocity

Earlier this month, I had written about  the Russian Arbitrazh court’s judgment before the Munich Court of Appeals (Oberlandesgericht) – the Munich court held that a Russian Arbitrazh Court is not an arbitral tribunal, and its judgment can not be recognized as an arbitral award under the New York Convention. The question then was asked whether in the alternative, the judgment of the Aribtrazh Court could have been recognized in Germany as a judgment of a state court. My short answer was that it could not, for lack of reciprocity. But the status quo has now been challenged. Read More