12.1 Enforcement of International & Foreign Awards

A foreign award consists of a foreign arbitration award and a foreign court award. A foreign award cannot be enforced in Indonesia. This is regulated by article 436 RV (Reglement op de Rechtsvordering) which stipulates that foreign court judgments (convicting decision) cannot be enforced in Indonesian territory because it is not the same or not equal to the decision of Indonesian court. This provision derives from the territo…