Enforcement Of Foreign Arbitral Awards Annulled At The Seat

Introduction

Enforcement
of
arbitral
awards
against
a
losing
party
who
refuses
to
comply
voluntarily
with
the
award
 is
consistent
with
the
mutual
intention
of
the
parties
to
resolve
their
differences
through
arbitration
and
 be
 bound
 by
the
resulting
 award.
 In
this
respect,
 judicial
 assistance
 ensures
the
 effectiveness
 of
 arbitration
as
a
private
arrangement
supported
by
national
and
international
legal
order. ¹ Thus,
the ability
to
enforce
arbitral
awards
obtained
in
one
country
within
the
jurisdiction
of
another
country
is
a
 significant
catalyst
for
the
success
of
international
trade
and
commerce.
The
New
York
Convention ² which
facilitates
this
objective,
nonetheless,
contains
normative
grounds
upon
which
enforcement
 courts
may
exercise
discretion
to
refuse
enforcement.

One of the most complex challenges of enforcement of awards arises when an award is annulled or set aside at the seat of arbitration. While some jurisdictions uphold such annulments, others may still recognize and enforce the award, leading to legal uncertainties and jurisdictional conflicts. This article explores the challenges surrounding the enforcement of foreign arbitral awards, particularly in cases where the award has been annulled at the seat, and examines the divergent approaches taken by courts worldwide.

ENFORCEABILITY
OF
FOREIGN
ARBITRAL
AWARDS

The
purpose
of
arbitration,
which
reflects
the
intrinsic
element
of
the
parties'
agreement,
is
to
arrive
at
a binding
 decision
 on
 the
 dispute.³ This
 element
 is
 set
 out
 in
 most
 leading
 international
 rules
 of arbitration
such
as
the
UNCITRAL
Rules, ⁴ the
ICC
Rules,⁵ and
LCIA
Rules.⁶ Implicit
in
the
consent
to
 arbitrate
is
that
the
resulting
award
will
be
binding
and
the
parties
will
comply
without
the
necessity
of
resorting
to
national
courts
for
enforcement. ⁷ While
voluntary
performance
of
the
award
is
expected,
 which
is
relatively
a
common
practice,
there
are
instances
where
the
losing
party
may
feel
dissatisfied
 with
the
arbitral
award
and
refuse
to
comply
thereto.
In
this
case,
the
winning
party
will
need
to
take
 steps
to
give
effect
to
the
award.
The
relief
against
a
losing
party's
refusal
to
perform
the
award
is
for
the
 winning
party
to
 seek
enforcement
proceedings
in
a
national
court,
a
possibility
contemplated
by
the
 parties
from
the
outset
of
the
arbitration.
In
this
regard,
an
arbitral
award
is
compared
to
a
binding
 decision
of
a
national
 court,
but
unlike
the
national
 court,
an
arbitral
tribunal
 cannot
enforce
its
 decision.


Generally,
recognition
and
enforcement
relate
to
 giving
 effect
to
the
 award,
 either
 in
the
 State
 where the award was made (primary
 jurisdiction)
or
in
some
other
States
(secondary
 jurisdiction).
Enforcement
of
award
in
the
State
 of
origin
or
'seat'
of
the
arbitration
is
relatively
 easy
 and
 subject
 to
 the
 regime
 applicable
 to
 domes ti c arbitration. However, when
 enforcement
is
sought
outside
the
territory
of
the
 State
 where
 the
 award
 was
 made,
 the
 award
 as sumes the charac ter of 'foreign' or
 'international award, and presents a more
 complex
 situation.
The
enforcement
of
foreign
 awards
 is
 guided
 by
 private
 international
 law
 principles
 of
 party
 autonomy
 and
 respect
 for
 parties'
contracts
which
has
become
the
forte
of
 the
New
York
Convention.⁸

ENFORCEABILITY
OF
FOREIGN
ARBITRAL AWARDS
UNDER
THE
NEW
YORK CONVENTION

The
New
York
Convention
1958
("Convention")
 is intended to facilitate the recognition and
 enforcement of international arbitration
 agreements
and
awards,
by
adopting
 "uniform
 international standards mandating the
 presumptive
validity
of
such
awards
and
limiting
 the c ir cu m s t anc e s f o r deny ing the ir
 recognition."⁹ The policy objective of the Convention is to promote cross-border
 arbitrations by providing an international
 minimum standard of rules to encourage
 international trade and commerce.¹⁰ The Convention
generally
applies
to
"the
recognition
 and
enforcement
of
arbitral
awards
made
in
the State
where
the
recognition
and
enforcement
of
 such awards are sought, and arising out of
 differences
 between
 persons,
whether
 physical
 or
legal."¹¹ To
this
end
therefore,
Article
III
of
the Convention
 mandates
 Contracting
 States
to
 "recognize
 arbitral
 awards
 as
 binding
 and
 enforce
them
in
accordance
with
the
rules
of
 procedure
of
the
territory
where
the
award
is
 relied
 upon"
 and
 also
 charges
 them
 not
 to
 impose "substantially more onerous
 conditions ... on the recognition or
 enforcement
of
arbitral
awards
to
which
this
 Convention
applies than
are
imposed
on
the
 recognition or enforcement of domestic
 arbitral
awards."

 The
advent
of
the
Convention
is
also
aimed
at
addressing
the
inadequacies
of
the
Geneva
Protocol
on
 Arbitration
Clauses
of
1923
and
the
Geneva
Convention
on
the
Execution
of
Foreign
Arbitral
Awards
of
 1927
(which
existed
prior
to
the
Convention).
One
of
such
inadequacies
is
the
requirement
that
an
 award
 must
 be
 final
 in
 the
 forum
 State.
 Specifically,
 it
 provides
 that
 to
 obtain
 recognition
 or
 enforcement,
it
is
necessary
to
prove
that
the
"award
has
become
final
in
the
country
in
which
it
was
 made,
in
the
sense
that
it
will
not
be
considered
as
such
if
it
is
open
to
opposition,
appeal..." ¹² This
was
interpreted
to
mean
that
the
award
has
to
be
declared
as
'final'
by
the
court
of
the
seat
of
arbitration
(the
 first
 "exequatur")
as
a
condition
for
its
recognition
and
enforcement
in
a
foreign
jurisdiction
 (the
 second
exequatur).
Where
either
court
denies
exequatur,
the
award
will
not
ultimately
be
recognized
 and
enforced.
This
greatly
undermined
the
efficacy
of
the
1927
Geneva
Convention,
by
making
the
 processes
cumbersome,
slow,
and
uncertain,
notwithstanding
that
the
parties'
dispute
has,
supposedly,
 been
finally
resolved
by
arbitration.¹³ In
addressing
these
inadequacies,
the
Convention
deliberately
uses
the
text
'binding'
to
avoid
the
problematic
double
exequatur.
This
reflects
global
best
practices
of
 encouraging
the
finality
of
arbitral
awards,
regardless
of
where
they
were
issued. ¹⁴ It
does
not,
however,
 mean
that
national
courts
do
not
possess
residual
powers
upon
application,
to
determine
within
the
 narrow
compass
allowed
by
the
applicable
law
and
other
rules
of
procedure,
whether
the
award
is
 binding
on
the
parties.¹⁵ This
discretion
implies
that
even
where
there
exists
a
ground
for
refusal
to
enforce
such
as
annulment
of
award
at
the
seat,
a
foreign
court
may
still
enforce
it. ¹⁶

IMPACT
OF
THE
SEAT
OF
ARBITRATION
ON
THE
ARBITRAL
AWARD

The
seat
of
arbitration
plays
a
crucial
role
in
arbitration
as
it
directly
influences
several
key
aspects
of
 the
arbitration
process
such
as
arbitrability,
determination
of
the
governing
law
(both
substantive
and procedural),
annulment,
recognition,
and
enforcement
of
the
arbitral
award
amongst
others. ¹⁷ The
 "Seat"
of
arbitration
refers
to
the
jurisdiction
or
location
in
which
the
arbitration
is
officially
regarded
as
 taking
place
for
the
purpose
of
determining
the
law
(lex
arbitri
or
lex
loci
arbitri)
that
will
govern
the
 arbitration
proceeding.
Put
differently,
it
is
the
legal
address
of
arbitration,
establishing
its
connection
to
a
particular
legal
system. ¹⁸ It
is
important
to
state
that
the
seat
of
arbitration
need
not
necessarily
be where individual procedural activities are
 conducted,
especially
where
hearings
are
held.
 Thus,
a
case
can
be
entirely
resolved
without
the
 arbitrators
 and/or
 parties
 having
 to
 visit
 the
 designated
 seat
of
arbitration.
However,
while
 the
 seat
 may
 differ
 from
 the
 place
 (physical
 location)
 where
 proceedings
 occur,
 both
 are
 typically aligned in guiding the arbitration
 process.
This
is
more
so
as
most
arbitration
laws
 usually
 specify
that
the
place
or
venue
 should
 help
determine
the
relevant
court's
jurisdiction
 when
the
parties
have
not
expressly
designated
a
 seat
of
arbitration.
As
such,
the
seat
and
venue
of
 arbitration
are
inextricably
linked.¹⁹

Therefore,
the
choice
of
the
seat
of
arbitration
is
 crucial,
as
it
defines
the
 applicable
 arbitration
 law
and
establishes
the
court
with
supervisory
 jurisdiction
 over
 the
 arbitration
 process.
 This
 choice
affects
both
the
recognition
of
arbitration
 agreements and the enforcement of arbitral
 awards. In the context of an arbitration
 agreement,
the
arbitration
law
of
the
jurisdiction
 that
issued
a
decision
on
the
validity
and
scope
of
 the
 agreement
 governs
 the
 arbitral
 procedure
 and
establishes
the
grounds
on
which
the
court
 of the seat of arbitration may annul the
 agreement
and
or
the
award.
This
implies
that
if
 an
aggrieved
party
seeks
to
challenge
the
award
 in
a
court
other
than
the
court
of
the
seat,
the
 doctrine
of
res
judicata
may
apply,
as
only
the
 court
of
the
seat
has
the
authority
to
annul
(set
 aside
or
vacatur)
the
award
 made
by
the
arbitral
tribunal.²⁰ Put
differently,
it
is
only
the
courts
of
 the
 seat
 of
 arbitration
that
 have
the
 exclusive
 competence to annul or set aside arbitral
award,²¹ and
to
that
extent,
it
is
only
decisions
of the
courts
of
the
seat
that
have
legal
relevance, ²² regarding
the
annulment
of
arbitral
awards.
This
 has been confirmed by numerous court
decisions²³ and
 the
 New
 York
 Convention
 has
 restricted
the
courts
where
the
annulment
of
an
 international
 arbitral
 award
 can
 be
 pursued, specifically
to
the
courts
of
the
seat. ²⁴

Further
to
the
 above,
 international
 arbitration
 is
typically
 subject
to
 a
two-tier
 system
 of
 judicial
 oversight,
namely,
the
court
of
the
arbitral
seat
(primary
jurisdiction)
and
courts
of
other
states
where
 recognition
and
enforcement
of
awards
are
sought
(secondary
jurisdiction).
The
courts
of
secondary
 jurisdiction
can
only
recognize
and
enforce
foreign
awards,
after
due
consideration
of
the
grounds
for
 refusing
foreign
arbitral
awards.
However,
it
does
not
have
the
vires
to
set
aside
or
annul
an
award
 issued
by
a
primary
jurisdiction
tribunal.

It
follows
that
enforcement
courts
lack
jurisdiction
to
set
aside
foreign-seated
arbitral
awards,
as
such
 awards
are
governed
by
the
provisions
of
international
instruments
such
as
the
New
York
Convention
 and
the
UNCITRAL
Model
Law.
However,
in
some
cases,
some
enforcement
courts
have
misconstrued
 an
application
to
resist
enforcement
of
a
foreign
award
as
an
attempt
to
set
aside
the
award.
One
of
such
 instances
was
captured
in
the
case
of Limak
Yatirim,
Enerji
Uretim
Isletme
Hizmetleri
Ve
Insaat
A.S.
&
Ors
V.
Sahelian
Energy
and
Integrated
Services
Limited, ²⁵ where
the
Court
of
Appeal
of
Nigeria
 held
that:

In
this
regard,
it
is
submitted
that
the
attitude
of
 the
Nigeria
court
and
or
any
other
enforcement
 court
in
misconstruing
an
application
to
resist
 enforcement
 of
 a
 foreign
 award
 to
 mean
 an
 application
 to
 set
 aside
 foreign
 awards,
 risk
 contravening established principles of
 international arbitration. Such actions could
 undermine
 the
 reputation
 of
 such
 secondary
 juri sdiction as an arbitration-friendly
 jurisdiction.
 Consequently,
 such
 provisions
 of
 the
 secondary
jurisdiction's
municipal
laws
 on
 setting
 aside
 arbitral
 awards
 must
 be
read
 to
mean
setting
aside
arbitral
awards ²⁶ obtained
in
 that
jurisdiction
and
not
foreign
arbitral
awards.

GROUNDS
FOR
REFUSING
ENFORCEMENT OF
FOREIGN
ARBITRAL
AWARDS

Notwithstanding the general presumptive
 enforceability
of
awards
under
the
Convention,
a
 Contracting
State
may
refuse
to
enforce
foreign
 awards
where
the
losing
party
establishes
any
of
the
recognized
grounds. ²⁷ The
grounds
represent
 an
internationally
accepted
 standard,
not
only
 because of the wide acceptability of the
 Convention
 but
 also
 because
 the
 UNCITRAL
 Model
Law
adopts
similar
grounds
for
refusing
 the
recognition
and
enforcement
of
awards
by
courts
 of
 secondary
 jurisdiction.²⁸ While
 these
 grounds
may
be
relied
upon
by
a
court
where
 enforcement
 is
 sought,
 these
 grounds
 do
 not
 permit
any
review
on
the
merits
of
the
award
to which
the
Convention
applies. ²⁹

Article
V(1)(a-e)
of
the
Convention,
sets
out
five
 different
grounds
upon
which
recognition
and
 enforcement of an arbitral award "may" be
 refused
at
the
instance
of
the
losing
party
against
 whom
the
award
is
sought
to
be
enforced.
One
 such
ground
which
is
the
focus
of
this
article
is
 the
provision
of
Article
V(1)(e)
which
provides
 that
"the
award
has
not
yet
become
binding
on
 the
parties
or
has
been
set
aside
or
suspended
by
 a
competent
authority
of
the
country
in
which,
or
 under
the
law
of
which,
that
award
was
made."
 Contextually,
a
major
consideration
for
a
losing
 party
to
file
an
application
before
a
competent
 authority
in
the
seat
of
arbitration
for
annulment
 or
set
aside
of
the
award
is
a
presumption
that
if
 the
award
is
set
aside
or
annulled,
there
is
a
high
 probability
that
its
enforcement
"will
be
refused
in
 any
 other
 jurisdiction
where
it
is
 sought."³⁰ Ideally,
 the
 decision
 of
 the
 court
 of
 the
 seat
 should presumably be determinative of the
 continued
validity
of
the
award,
for
purposes
of enforcement.³¹

Expectedly,
Article
V
(1)(e)
ground
has
generated
a
lot
of
controversy
and
legal
debate,
firstly,
because
 of
the
assumption
that
if
an
award
has
been
set
aside
in
the
country
of
its
origin,
it
is
unenforceable
in
 that
country
by
the
doctrine
of
res
judicata,
and
that
it
is
only
a
matter
of
international
comity
or
indeed
the
principle
of
reciprocity
that
"courts
of
other
States
would
also
regard
the
award
as
unenforceable," ³² and
secondly,
because
there
is
a
discretion
on
the
enforcement
court
to
determine
how
to
deal
with
such
 awards.
As
would
be
seen
subsequently,
courts
of
some
jurisdictions
recognize
and
enforce
awards
 annulled
or
set
aside
at
the
seat.

ENFORCEMENT
OF
ANNULLED
AWARD
UNDER
THE
NEW
YORK
CONVENTION

As
earlier
observed,
the
Convention
mandates
general
recognition
and
enforcement
of
arbitral
awards.
 However,
 it
 also
 provides
 exhaustive
 grounds
 for
refusal
 of
recognition
 and
 enforcement,
 which
 includes
annulled
or
set
aside
awards.
Both
Article
34
of
the
UNCITRAL
Model
Law
and
Article
V
(1)(e)
 of
the
Convention
empower
a
competent
authority
in
the
seat
of
arbitration
to
annul
or
set
aside
an
 award.
This
residual
power
of
a
competent
authority
(oftentimes
a
court
designated
for
supervisory
 jurisdiction
over
arbitration)
in
the
country
of
origin
of
an
award
to
annul
or
set
aside
an
award
permits
 a
check
on
the
arbitral
process,
which
is
why
arbitrators
are
encouraged
to
render
an
enforceable
 award.

Presumptively,
the
fact
of
an
award
having
been
set
aside
or
annulled
in
the
seat
of
arbitration
which
 makes
it
unenforceable
therein
 should
necessarily
 commend
 a
refusal
of
 enforcement
where
it
is
 sought.
This
 suggests
that
 annulment
is
notionally
intended
to
have
 an
 extra-territorial
 effect,
 as
annulled
awards
may
be
refused
enforcement. ³³ In
any
event,
Article
VI
of
the
Convention
permits
a
 national
court
before
which
an
application
for
recognition
and
enforcement
is
made,
to
adjourn
the
 application
where
there
is
a
pending
set-aside
proceeding
at
the
seat
of
the
arbitration.
Given
that
the
 language
of
Article
V(1)(e)
is
rendered
in
a
permissive
character
in
the
same
manner
as
Article
36(1)
of
 the
Model
Law,
entitling
a
court
where
enforcement
is
sought
to
a
discretion
whether
to
enforce
the
 award
despite
its
set
aside,
one
would
expect
that
the
provisions
would
be
interpreted
in
the
same
way
 by
national
courts
across
various
jurisdictions.
As
a
multilateral
treaty
on
private
international
law,
it
is
 to
be
expected
that
consistent
with
Vienna
Convention
on
the
Law
of
Treaties,
the
provisions
of
Article
V
 of
the
New
York
Convention
will
be
interpreted
"in
good
faith
in
accordance
with
the
ordinary
meaning to
be
given
to
the
terms
of
the
treaty
in
their
context
and
in
the
light
of
its
object
and
purpose." ³⁴

Footnotes

1. E.
Onyema,
'IPCO
v
NNPC
Saga
and
Liability
of
Nigerian
Legal
System',
The
Guardian
(Nigeria,
22
December
2015) https://guardian.ng/features/law/ipco-v-nnpc-saga-and-liability-of-nigerian-legal-system/,
accessed
9 ^th September
2024.

2. Convention
on
the
Recognition
and
Enforcement
of
Foreign
Arbitral
Awards,
New
York,
10
June
1958,
United
Nations
Treaty
Series,
vol.
330,
No.
4739
[hereinafter:
the
New
 York
Convention
or
the
Convention].

3. Nigel
Blackaby
Et
al
(7 
Edition)
2023,
Kluwer
Law
International;
Oxford
University
Press,
P.
11.1

4. UNCITRAL
Rules,
Art.
34.2

5. ICC
Rules,
Art.
35.6

6. LCIA
Rules,
Art.
26.8.

7. See
Queen
Mary
University
of
London,
School
of
International
Arbitration,
and
White
&
Case
LLP,
2018
International
Arbitration
Survey:
The
Evolution
of
International
 Arbitration,
available
online
at
http://www.arbitration.qmul.ac.uk/media/arbitration/docs/2018-InternationalArbitration-Survey-repor...,
p.
7,
which
found
that
64
per
 cent
of
arbitration
users
consider
that
'enforceability
of
awards'
is
the
most
valuable
characteristic
of
arbitration.

8. The
New
York
Convention
also
applies
to
arbitral
awards
that
are
'not
considered
as
domestic
awards
in
the
State
where
their
recognition
and
enforcement
is
sought'
(Art.
1(1)).

9. Gary
B.
Born,
International
Commercial
Arbitration,
(3 Ed.,
2021),
Kluwer,
§26.03;
Mobil
Cerro
Negro
Ltd
v.
Venezuela,
87
F.Supp.3d
573,
594
(S.D.N.Y.
2015)
("The
New
York
Convention
was
negotiated
 in
1958 and
entered
into
force
in
1959.
It
was
adopted
to
facilitate
international
enforcement
of
arbitral
awards");
Four
Seasons
Hotels
&
Resorts
BV
v.
Consorcio
Barr,
SA,
613
F.Supp.2d
1362,
1367
(S.D.
Fla.
2009)
 ("'there
is
a
general
pro-enforcement
bias'
manifested
in
the
Convention")

10. Albert
Jan
van
den
Berg,
Enforcement
of
Arbitral
Awards
Annulled
in
Russia:
Case
Comment
on
Court
of
Appeal
of
Amsterdam,
27(2)
J.
INT'L
ARB.
181
(2010);

E.
Gaillard,
Legal
Theory
of
 International
Arbitration
(Martinus
Nijhoff,
2010),
136

11. Article
1(1)
of
the
New
York
Convention

12. Article
1(d)
of
the
Convention
on
the
Execution
of
Foreign
Arbitral
Awards
Signed
at
Gevena
on
the
26 day
of
September
1927;
See
also
Article
4
(2)
of
the
Geneva
Convention.

13. Born,
Gary
B.,
supra
note
14.

14. Lew
J.M.D,
Mistelis
L.A
&
Kroll
S.M.,
(2003)
Comparative
International
Commercial
Arbitration,
Kluwer,
p.20.

15. See
Articles
34
and
36,
UNCITRAL
Model
Law;
Article
V,
New
York
Convention.

16. Article
V
(1)(e)
of
the
Convention.

17. Alexander
J.
Belohlavek,
"Seat
of
Arbitration
and
Supporting
and
Supervising
Function
of
Courts"  https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2593428 accessed
on
5 November
2024.

18. Loukas
Mistelis.
(2016).
Seat
of
Arbitration
and
Indian
Arbitration
Law
Indian
Journal
of
Arbitration
Law,
No.
4.

19. Gonzalo
Vial,
"Influence
of
the
Arbitral
Seat
in
the
Outcome
of
an
International
Commercial
Arbitration"
(2017)
(50)
2
International
Lawyer
332.

20. Nnaemeka
Nweze
&
Festus
Okechukwu
Ukwueze
'The
Effect
of
Arbitral
Jurisdictional
Decision
on
National
Courts'
[2023]
(16)
(2)
Contemporary
Asia
Arbitration
Journal
207.

21. Albert
Jan
van
den
Berg,
Should
the
Setting
Aside
of
the
Arbitral
Award
be
Abolished?,
29
ICSID
Review
 266
(2014)

22. Tibor
Varady
et
al.,
International
commercial
arbitration:
A
transnational
perspective
1135
(6
ed.
2016).

23. In
International
Standard
Electric
Corp.
v.
Bridas
Sociedad
Anonima
Petrolera,
745
F.
Supp.
172
(S.D.N.Y.
1990),
ISEC
filed
a
petition
in
the
United
States
district
court
to
vacate
the
award.
This
was
 dismissed
as
the
court
held
that
it
lacked
subject
matter
jurisdiction
to
vacate
a
foreign
arbitral
award.
This
is
because
the
parties
had
elected
to
apply
the
procedural
law
of
Mexico,
and
as
the
governing
 procedural
law
was
that
of
Mexico,
only
Mexican
courts
had
jurisdiction
to
vacate
the
award.

24. Articles
V
(1)(e)
&
V
of
the
Convention;
Also
see
Articles
6
and
34
of
the
UNCITRAL
Model
Law.

25. (2021)
LPELR-56408(CA)

26. Section
55
of
the
Arbitration
and
Mediation
Act
2023.

27. Article
V.

28. Articles
34
and
36.

29. The
Supreme
Court
of
India
in
Renusagar
Power
Co.
Ltd
v
General
Electric
Co.
(1995)
XX
YBCA
681
at
691,
held
that
'the
scope
of
enquiry
before
the
court
in
which
the
award
is
sought
to
be
enforced
is
 limited [to
the
grounds
mentioned
in
the
Act]
and
does
not
enable
a
party
to
the
said
proceedings
to
impeach
the
Award
on
merits'.
See
also
Nigel
Blackaby,
supra
note
16,
at
P.
11.55

30. Tripkovic,
Jelena
(2018)
Enforcement
of
Arbitral
Awards
set
aside
in
the
country
of
origin,
Central
European
University,
p.
1.

31. Karaha
Bodas
Co.
LLC
v.
Perusahaan
Pertambangan
Minyak
Dan
Gas
Bumi
Negara,
364
F.3d
274
(5th
Cir.
2004

32. Nigel
Blackaby,
supra
note
9,
at
P.
11.91.

33. Van
den
Berg,
supra
note
53,
at
4

34. Article
31(1)
of
the
Vienna
Convention
on
the
Law
of
Treaty
of
23 
May,
1969

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