Curiouser And Curiouser: The Enforcement Of Arbitration Awards

Arbitration has always represented one of the less flashy aspects of dispute resolution, not least because of its informality and addiction to commercial common sense, where parties recognise that they want to avoid the high drama of eighteenth century dress, forms of address and liturgy. Altogether a good thing. To that end, in the Isle of Man we have the Arbitration Act 1976 (the Act), modelled on the 1950 Act of Parliament of the same name, blending into it some of Parliament's afterthoughts.

The Act deals in Part I, with domestic arbitration and arbitration agreements. Part I does not purport to have extra-territorial effect upon the constitution or effect of arbitration proceedings taking place outside of the Isle of Man under foreign laws. This principle was confirmed in the English Court of Appeal in International Tank and Pipe S.A.K. v Kuwait Aviation Fuelling Co. K.S.C [1975] Q.B. by Lord Denning Master of the Rolls, confirming that the preliminary question