There is a shift in international law.
Earlier, if some arbitration award was made against some parties in US, it has to be first confirmed by a US court, only thereafter, this award or decree can be executed in India.
But after New York Convention is adopted by India under 1996 Arbitration Law, aforesaid requirement of prior confirmation by foreign court is not necessary.
Case : E v U reported in 2014 (1) SCALE 44
Haresh Raichura
1039
