KIND OF
ARBITRAL
AWARD
SEAT
CONFIRMATION/
RECOGNITION
CORRECTION BY
THE COURT
(what kind of judicial act
necessary for enforcement
of award)
(can the AA be
corrected by the court)
SETTING
ASIDE/
VACATION
(can the court
vacate or set aside
the AA)
Domestic
Arbitral Award
PH
CONFIRMATION
YES
YES
Domestic ICA
Award
PH
NO
Foreign ICA
Award
Foreign
Convention
and As-In
Convention
Award
Purely NonConvention
Award
OPH
RECOGNITION
(UNCITRAL Model
Law & ADR Act)
RECOGNITION
NO
NO
OPH
RECOGNITION
NO
NO
OPH
RECOGNITION
(but
not under ADR Act, but
under ROC)
NO
NO
COMBINATION
OF CAUSES OF
ACTION
(procedural)
SIMILARITY
OF GROUNDS