The question is how Article V(2)(b) of the New York Convention is to be interpreted.

As explained above, each party to the New York Convention has to interpret its obligations under the Convention in good faith in accordance with the natural and ordinary meaning to be given to the terms of the treaty in the context and in light of its object and purpose. Thereby, the preamble and annexes and any instrument drawn up in connection with the conclusion of the Convention must be included.1

Any analysis has to start by recognizing that Art. III of the New York Convention imposes on each party to the Convention the duty to recognize and enforce a foreign award if it is not entitled to refuse such recognition or enforcement under Art. V. Obviously Art. V is an exception to the general duty to recognize and enforce a foreign award. Under general interpretation rules applicable in civil law countries exceptions have to be interpreted narrowly.2 But this rule does not generally demand a narrow interpretation of the terms stipulated in Art. V; this term has to be interpreted in light of its object and purpose and the intention of the parties. By qualifying the term public policy with "of that country" it has to be accepted that the Conference did not try to find a transnational meaning of public policy.3