Question juridique clé
Whether an enforcement certificate under Art. 193(2) IPRG binds the legal-opening judge for a Swiss-seated international arbitral award
Solution extraite
Yes. The legal-opening judge must accept the enforcement certificate as proof of enforceability and may not review the procedure by which it was issued.
Motifs extraits
The court held that the certificate is a qualified proof of finality and enforceability; prevailing doctrine supports binding effect, and the legal-opening judge is not competent to examine the issuing court's decision.