Libyan General National Maritime Co contracted with Gotaverken Arendal for three oil tankers. Arbitration clause stipulated that arbitration was going to take place in Paris under ICC rules.
Eventually, a dispute arose when Lybian General National Maritime Co refused to take delivery of the oil tankers. As a result, an award was rendered in favour of Gotarverken Arendal. Afterwards, GNMTC appealed against the award before French courts to have the award set aside on various grounds.
Held: The award was international and French courts have no jurisdiction to set it aside “the place of the arbitral proceedings, chosen only in order to assure their neutrality, is not significant”. Award was finally enforced in Sweden without any review on the basis that it is a “foreign award”.