for only very limited reasons. These restrictions are imposed in order to safeguard the finality of awards, to limit uncertainty and to prevent ongoing disputes after an award has been made.
It is clear that only very narrow categories of “errors” may be corrected
under the Model Law. In particular, only “errors in computation, . . . clerical
or typographical errors or . . . errors of similar nature” may be corrected.
Article 33(1) is directed towards simple arithmetic mistakes in calculation or
typographical errors (e.g., failure to include one of a number of categories of
damages which have been found payable in the dispositive section of the
award, when this was clearly intended).
In contrast, errors in the tribunal’s reasoning in the body of its award are not
subject to correction. As courts in some Model Law jurisdictions have reasoned, an arbitral tribunal is not authorized by Article 33 to correct errors of
judgment, whether of law or fact.
Even if a tribunal demonstrably misunderstands or overlooks some critical
provision of the parties’ agreement or some essential piece of evidence, the
remedy is not generally correction of the award under Article 33, but rather
an application to annul.
(Italics in original; citations omitted)
 According to Nigel Blackaby and Constantine Partasides,
Redfern and Hunter on International Arbitration, 6th ed. (Oxford:
Oxford University Press, 2015), at p. 565, the purpose of
art. 33(3) dealing with additional awards “is to ensure that the
arbitrators may complete their mission if they have omitted from
their award decisions in relation to any of the claims presented in
 The respondents’ stated intention to seek costs relating to
the set aside and enforcement proceedings Mr. Popack took in the
Ontario courts certainly does not constitute a computational,
clerical or typographical error in the Award, nor a request to
make an “additional award” as to “claims presented in the arbitral proceedings but omitted from the award”.
 The respondents’ stated intention is based on events that
took place after the Award was made; it raises a “new issue”.
I note that respondents’ counsel, in cross-examination of
Mr. Popack on his affidavit, accepted that Mr. Lipszyc’s claim for
costs incurred after the issuance of the Award in the Ontario
court proceedings was a “new issue”. Article 33 does not apply in
 The respondents point to the decision of the Federal Court,
Trial Division, in Relais Nordik Inc. v. Secunda Marine Services
Ltd.,  F.C.J. No. 349, 1990 CarswellNat 1320 (T.D.) to support their position. Although in that case the court refused recognition of an award on the ground it was “not yet binding” on the
parties, the facts of that case bear no resemblance to those in this
case. The Relais Nordik case concerned an arbitration governed