During the global festivities that accompanied the fortieth anniversary of the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards in 1998, practitioners from around the world congratulated each other on its astounding success. With over 120 jurisdictions as signatories, the New York Convention is undoubtedly the most successful treaty of its kind. Arbitration is established as the mode of choice for the resolution of international commercial disputes. However, in our enthusiasm we must not forget that there remains a great deal to be done. Nowhere is this more evident than in a decision of the Pakistan Supreme Court released in June of last year.