In Henry (Chaim) Konig & Anor v Menachem Arieh Zwiebel & Anor [2009] the Court of Appeal considered whether notice given to the appellant of an arbitration award was effective.

The case involved a dispute arising from the disposal of assets in relation to property between two Orthodox Jews. Failing to be settled in accordance with Jewish law, the case was subsequently referred for independent arbitration proceedings under the Arbitration Act 1996. The appellant, Konig, argued that notice of the Tribunal's award was ineffective because it was given indirectly by the Respondent's solicitors instead of directly from the tribunal. The court held that it was irrelevant that the appellant had notice of the award indirectly; s.76 of the Arbitration Act 1996 allows for notice of an award to be given either directly or indirectly. Thus, once notice was given, the appellant had a 28-day period in which to challenge the award. Failing to do so meant that after this period, under s.73 of the Act, the award would take effect. The award did take effect after 28 days as the appellant, having received indirect notice of the award, failed to challenge it within the requisite period.