The effect of public order on the ability to refer to ‎arbitration in Iranian law and the New York Convention

The purpose of this paper is to explain the position and role of public policy in international commercial arbitration and to find the answer to the question of what is the relationship between public policy and mandatory rules? This study indicates that despite the existence of a series of similarities between public policy and mandatory rules, these two concepts are different from each other. Thus, public policy is not only an obstacle to the implementation of arbitration awards, but also mandatory rules can become a serious obstacle to the implementation of arbitration awards. In addition, the quality of performance and mechanism of these two legal entities with international commercial awards are also different when faced with international commercial arbitration awards Public policy is one of the most fundamental and well-established concepts in the history of law. Regardless of the differences in the definition of public policy, it can be considered as the most important obstacle to the implementation of arbitration awards.