Annulment of Arbitral Awards Due to Conflict with Public Order in Iranian and Turkish Law

The annulment of arbitral awards on the grounds of conflict with public order constitutes one of the most controversial issues in international arbitration law. This article, through a comparative-analytical approach and based on legal sources, judicial precedents, and doctrinal perspectives, examines the theoretical foundations and practical instances of annulment of arbitral awards within the legal systems of Iran and Turkey. The findings indicate that, in Iranian law, public order is primarily defined based on Islamic legal standards, whereas Turkish law, influenced by European Union standards and competitive legislation, offers a broader interpretation of public order. The divergence in legal foundations has led to differing approaches in the interpretation and scope of public order. This study, by analyzing judicial decisions and legal documents, proposes strategies to reduce these conflicts. Minimizing the disputes arising from the annulment of arbitral awards in Iran and Turkey necessitates a combination of legislative reforms, specialized training, and innovative technologies. While Turkey has made significant progress by aligning with the European Union, Iran requires a redefinition of public order within a more balanced framework that preserves Islamic values without neglecting international obligations.