law to govern both the substance and the procedure of the arbitration had the effect that section 48 of the Act did not apply. Where, as English law allows, parties in a London-seated arbitration choose for the Act to apply but choose a different procedural law, the Act will apply as a residual framework to fill gaps, as well as by reason of mandatory provisions. Since section 48 is not a mandatory provision, and Jewish law covers the matter of remedies including the Beth Din’s powers to transfer title to Property, section 48 does not apply. Therefore, even if the Defendants had raised this objection in good time, it would have been rejected. The Beth Din had the power to order the transfer of the Property under Jewish law. (2) If the Beth Din lacked such a power, does the Court have the power to order the transfer itself? Because the Court held that the Beth Din did have power to make the order, it was not necessary for the Court to decide this question. However, the Court held that it would have been willing to find that it had jurisdiction under section 66 of the Act to make an order transferring the Property even if the Beth Din lacked the power to make such an order. The Court said that its discretion on enforcement is unfettered and it has wide power to give effect to an award. (3) Should the Court exercise its discretion under section 66 of the Act to enforce the Award? The Court said that any arbitration award that has not been challenged is final and treated as binding. It should ordinarily be enforceable, and section 66 (which gives the Court the power to enforce arbitration awards) should be a straightforward remedy for achieving that. However, the Court also noted that it has a wide discretion in deciding whether to enforce, and that section 66 is never a “rubber-stamping exercise”. In particular, the enforcement of a mandatory injunction is more likely to generate specific consideration than the enforcement of a monetary award. Specific performance is an equitable remedy and will not be granted by the Court if it interferes with the rights of third parties, or if a party has not come to court with clean hands. On this basis, the Court held that the new evidence produced in relation to the Claimant’s conduct meant that it would be inequitable for the Court to enforce the Award.