Chimezie Onuzulike in his article, Enforcement of Arbitral Awards: Navigating the Uncertainties of Public Policy Defence, examines the contemporary trends in public policy defence as a ground for resisting the enforcement of or setting aside arbitral awards. One of the reasons for the attractiveness of arbitration is the finality of the resulting award. Although in principle, arbitral awards are final -and should in fact be so-, in practice this is not necessarily so. Award debtors always find reasons to resist the enforcement of awards, or worse, to apply to set them aside on one of the permissible grounds. One of such permissible grounds is the public policy ground. Public policy is a relative concept dependent on the prevailing moral, social, political, economic or legal principles of each state. Since public policy Is based on application of a state’s legal principles and values, States continue to expand the list of acts that may be seen as contrary to public policy. Recently, the Russian Courts in two cases refused enforcement of an arbitral award on public policy grounds because- in one case- the award creditor, and- in the other case- the arbitrators were nationals of a country deemed ‘unfriendly’ under Russian legislation.