Jurisdiction(s):
United Kingdom
Related legal acts
Key definition
Enforcement definition

What does Enforcement mean? Enforcement is the practical process of making a court order, judgment, decree or arbitral award take effect when the party bound has not complied by the deadline. It involves applying for, and using, court-sanctioned measures to secure compliance or recover sums due, including where permission is required. The term is descriptive rather than a single statutory definition; the available remedies depend on the jurisdiction and the nature of the order. England and Wales: governed mainly by CPR Parts 70–73, including writ/warrant of control, third party debt orders, charging orders (and orders for sale), attachment of earnings, possession and delivery up, appointment...

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Defendant’s witness statement template resisting enforcement of New York Convention awards in England and Wales under Arbitration Act 1996 sections 101 and 103

Precedents
imgtext

Lodged on behalf of the Defendant

Witness statement of [ insert initial and surname of witness ]

  • Number of witness statement: [ insert number of witness statement in relation to the witness ]
  • Exhibit details: [ insert initials and number of each exhibit referred to ]
  • Date on which statement was made: [ insert date ] [ Date of translation: [ insert date ] ]

CLAIM NO: [ insert claim number ]

IN THE HIGH COURT OF JUSTICE, Business and Property Courts of England and Wales, Commercial Court (KBD)

OR

In the High Court of Justice, Business and Property Courts in [ insert location ] [ specify division ] [ specify specialist court ]

BEFORE [ insert judge’s name ]

AND IN AN Arbitration CLAIM

Between 1 [ insert Claimant’s name ] Claimant -and- 2 [ insert Defendant’s name ] Defendant

AND IN THE MATTER OF AN ARBITRATION

Between 1 [ insert Claimant’s name ] Claimant -and- 2 [ insert Respondent’s name ] Respondent

WITNESS STATEMENT OF [ insert witness’s name ]

I, [ insert witness’s name ], of [ insert address ], SAY AS FOLLOWS:

  1. This witness statement is made in support of...
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Hamid Khanbhai
Hamid Khanbhai chambers

Hamid specialises in commercial litigation and arbitration with an emphasis on insurance/reinsurance, construction law, maritime arbitration and litigation, and professional liability claims. He has experience of ad hoc and institutional arbitrations, and is familiar with ICC, LCIA, LMAA, and UNCITRAL arbitration rules....

Web page updated on 22/05/2026

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