An action for annulment is brought by a French real estate company and a financial company under Belgian law, against an internal arbitration award.

The appellants dispute the internal nature of the arbitration, arguing that the dispute concerns persons under French and Belgian law. The Court of Appeal dismisses the pleas on the ground that the registered office of the parties is not sufficient to characterize the internationality of the arbitration, and that the disputed transactions took place in France.

However, the Court of Appeal quashed the arbitration award after finding the violation of the adversarial principle, constituted by the conviction of a third party to arbitration to the payment of a provision, without having been heard or called.