Originally from The Enforcement of Foreign Arbitral Awards in Russia

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NY Convention article V(1)(c) and ICA Law article 36(1)(3)
provide that enforcement may be denied if the award deals with a
difference not contemplated by or not falling within the terms of the
submission to arbitration, or it contains decisions on matters beyond
the scope of the submission to arbitration. Both authorities further
provide that partial enforcement is possible: “if the decision on
matters submitted to arbitration can be separated from those not so
submitted, that part of the award which contains decisions on matters
submitted to arbitration may be recognized and enforced.”1 A twoprong
test is to be applied in article V(1)(c) cases. First, one
determines the scope of the arbitration clause; second, one
determines what matters the parties referred to the tribunal for
resolution, that is, the tribunal’s mandate.2 A full analysis of the
article V(1)(c) objections would require more information than in
generally available from the decisions. Accordingly, the examination
of the objection below is necessarily limited.