The international arbitration community takes pride in, and makes exceptionally good use of, the United Nations Convention of 1958 on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention). This is no surprise, given the importance of international arbitration in the resolution of international disputes, and the acute dependence of international arbitration on the mobility of awards. It was in consideration of the paramount importance of the Convention that the International Academy of Comparative Law commissioned a comparative study of the Convention’s application and interpretation by the national courts of contracting States. Like most international treaties, the Convention is only as good as the use that can be, and is, made of it. And, again like most treaties, its efficacy depends on the will and the ability of national courts to act in compliance with it. The present study does not reveal any pattern of deliberate departure from the letter or spirit of the Convention. The fact remains, however, that many of its provisions may be interpreted, in perfect good faith, in different ways. They may also be applied with different degree of rigor.