On June 13, 2023, the First Department issued a decision in Republic of Kazakhstan v. Chapman, 2023 NY Slip Op. 03211, holding that an arbitral award could not be challenged in court based on newly-discovered evidence, explaining:
There is a well-settled rule prohibiting challenges to arbitral awards on the basis of newly discovered evidence. Without such a rule, the arbitration award would be the beginning rather than the end of the controversy and the protracted litigation which arbitration is meant to avoid would be invited.
(Internal citations omitted).