Gol Linhas v MatlinPatterson

On an application to refuse recognition and enforcement of a New York Convention arbitral award, the enforcing court does not review the merits of the dispute; a tribunal applying the law on a basis not argued by the parties (iura novit curia / iura novit arbiter) does not, without more, deny due process, and a serious breach of due process need not be shown to have been causative of the outcome, but an issue estoppel may arise from a decision of the courts of the seat.