In dubio pro executione.

This article discusses stay of enforcement proceedings regarding foreign arbitral awards under Article VI of the 1958 New York Convention pending setting aside proceedings at the place of arbitration. It analyses three options (enforcement, stay with security and stay without security) and argues that foreign precedents and scholarly writing favouring the first two options are in line with the text and the policy objectives of the New York Convention and that a stay of the enforcement without security should only be granted in exceptional circumstances.