This article analyses the recognition and enforcement of foreign arbitral awards in Iran under the 1958 New York Convention, with particular attention to the interaction between Convention obligations and Iranian constitutional and procedural constraints. After clarifying the Iranian taxonomy of awards (domestic, international, foreign) and the resulting enforcement tracks under the Civil Procedure Code (CPC), the Law on International Commercial Arbitration (LICA 1997) and the New York Convention, the article maps the practical sequence of enforcement before Iranian courts, including jurisdiction, filing requirements, time limits, interim relief, stays, and security. It then synthesizes recent, largely unpublished judicial decisions to identify patterns in courts’ use of Convention Article V defences – especially public policy (including monetary regulations and Sharīʿa-based interest prohibitions), commerciality, arbitrability (with the overlay of Article 139 of the Constitution), and procedural objections (Article IV: documentation, service, and translations). While several chambers increasingly align with international best practices, recognizing their limited role vis-à-vis annulment at the seat and narrowing merits review, outcomes remain sensitive to documentary formalism and public-policy framing. The article concludes with practical drafting and filing guidance to enhance predictability when targeting assets in Iran, and policy suggestions on transparency and specialization to consolidate this evolving jurisprude.
Shahri et al. (2026) studied this question.