... to such a refusal by the defence known in civil law systems as the exceptio non adimpleti contractus (exception d'inexécution; Einrede des nicht eifüllten Vertrags). civil law common law defence of refusal to perform Einrede des nicht erfullten Vertrags England exceptio non...

... on insufficient legal reasoning. As Paulsson notes in his comment on the award: ‘The discussion of exceptio non adimpleti contractus … contains the only passages in the award that include an analysis of French case law and commentary.’ ¹⁴⁶ However, for present purposes the correctness...