Citrix Discussions - a community forum to discuss Citrix products and services. Meet Citrix experts and users. Ask questions about XenApp. Brian F Mambosho joined Clyde and Co Tanzania in from FK Law Chambers, a law firm based in Dar es Salaam where he undertook his practical training for more. Solutions Engineer (Global Citrix and EUC SME). Clyde & Co. Oct - Oct 5 years 1 month. London, United Kingdom. Clyde & Co LLP Graphic. CIS FORTINET BENCHMARK
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View our Climate Change Risk Practice. What clients say. Extensive experience in the financial services industry, especially in insurance, banking and intermediary services. Chambers Global They understand our business - the nature, scale and complexity of the organisation, the products we offer and our client base. Chambers Global Latest awards won. Go to next section Contact. The court made this finding on the basis that the ignorance of the res judicata effect of a foreign court decision does not in itself violate international public policy.
In another decision of 13 January , the French Cour de Cassation went even further. In that case, following French law and Article VII 1 of the New York Convention, the fact that an award rendered abroad has been set aside in the country of the seat is not a ground for refusing enforcement, even in the context of domestic arbitration.
The same rule was already established by the French Cour de Cassation on 17 October  but the issue had not been addressed since then. These decisions may surprise some practitioners, since they may alert the legal certainty that parties enjoy in domestic arbitration proceedings. However, they appear to be justified from a legal standpoint. Indeed, given the rules applicable in France, the same provisions on recognition and enforcement of arbitral awards apply whether the award is issued in an international or domestic arbitration located abroad.
This is further supported by the New York Convention, which does not restrict its scope to international awards but also applies to " arbitral awards made in the territory of a State other than the State where the recognition and enforcement of such awards is sought " Article I 1 of the New York Convention. Legal scholars have also explained the approach of the French courts by considering the private nature of an award.
On this basis, arbitral awards can be given legal effect in any jurisdiction and not only in that of the seat of arbitration. It therefore becomes coherent to recognize, in France, a foreign domestic award that has been set aside in the country of the seat of arbitration. Sirketi v. Norsolor S. Jolasry , 10 March , n. Omnium de Traitement et de Valorisation , 19 December , n. Chromalloy Aeroservices, Inc. Rena Holding, et al. Paris Court of Appeal, 11 January , n.
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