Arbitration

Dallah Real Estate and Tourism Holding Co v Ministry of Religious Affairs, Government of Pakistan [2011] 1 All ER 485 provided that a person who denied being party to any relevant arbitration agreement had no obligation to participate in the arbitration or to take any steps in the country of the seat of what he maintained to be an invalid arbitration, leading to an invalid award against him. The party initiating the arbitration had to try to enforce the award where it could. Only then and there was it incumbent on the defendant denying the existence of any valid award to resist enforcement.