Public Order: On the Problem of Institutionalization in the International Civil Procedure

Neither Russian nor foreign legislation has established criteria for determining public order, the understanding and guidance of which could provide stability and legal certainty for participants in disputes and economic relations. For procedural law and legal relations related to the execution of foreign court decisions and arbitrations, the contours of the definition of public policy are specific. The authors set out to consider the approaches that have developed in Russian law enforcement practice in terms of defining public policy as a criterion for checking the compliance of foreign arbitration decisions to be enforced in the Russian Federation, with the prospect of specifying Russian procedural legislation.