Agreements to arbitrate current and future commercial disputes are considered valid by Pakistani courts, although the courts retain jurisdiction in disputes referred to foreign tribunals. Under the Arbitration Act of TMT, a foreign award is considered binding as though it were a domestic award, subject to certain restrictions. Foreign awards are enforced upon application to the appropriate court having jurisdiction over the subject matter of the award. The authors of this article argue that, once a foreign award is final, the disputed issue should be considered res judicata, despite the fact that the issue has not been determined judicially. The article concludes with a brief discussion of private commercial arbitration in Pakistan.