Enforcement of Foreign Arbitral Awards: Application of the Public Policy Rule in Russia
Bibliographic record
Abstract
THE QUESTION of the application of the public policy rule is very important in issues of enforcement of foreign arbitral awards. Often, when all other grounds for refusal are not sufficient, the debtor relies on public policy as the last resort. Since public policy cannot be given a uniform understanding and each case must have an individual approach, a debtor might well be able to use this excuse to delay the enforcement proceedings and execution of the arbitral award. Understanding of public policy differs from state to state. In Germany, public policy is ‘good customs and the purposes of German law’. In the USA, it is ‘the most basic understanding by courts of morals and justice’,1 although this understanding may be widened by the ‘manifest disregard of law’ if, for example, an arbitral award grossly ignored certain imperative norms of a state, which as a result contradicts the public policy of that state.2 In Canada, public policy refers to the incompatibility of an arbitral award with the basic principles of public morals.3
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.008 | 0.017 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.007 | 0.005 |
| Scholarly communication | 0.010 | 0.003 |
| Open science | 0.002 | 0.005 |
| Research integrity | 0.005 | 0.006 |
| Insufficient payload (model declined to judge) | 0.003 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".