Written by Loi Pham & Tung Han – VILAF^[1]

Under Article 68.2.dd of 2010 Commercial Arbitration Law (“2010 CAL”), a (domestic) arbitral award will be annulled if it is contrary to the fundamental principles of Vietnam laws (“Statutory Fundamental Principles”). Published decisions of Vietnam courts show that this provision is one of the most common grounds referred by parties for the award annulment^.[2] However, the interpretation and application of this legal ground are quite troublesome in practice.

This article will thus (i) examine relevant regulations of Vietnam on setting aside a (domestic) award due to violation against the Statutory Fundamental Principles in comparison with the UNCITRAL Model Law, (ii) discuss key problems in interpreting and applying this statutory ground for award annulment in practice prior to (iii) making some suggestions with a view to improving the current award annulment reality in Vietnam.

(a) Ambiguity and broad interpretation of the concept of the Statutory Fundamental Principles

Historically, the concept of Statutory Fundamental Principle has existed in numerous legislative documents of Vietnam for a long time^[3]. However, in context of the award annulment, there was no official guidance about this concept until the issuance of Resolution No. 01/2014/NQ-HDTP on 20 March 2014 (“Resolution 01/2014”).

Accordingly, Article 14.2.dd of Resolution 01/2014 regulates that “an award contrary to the fundamental principles of Vietnam law means the award violates the basic principles on conduct the effect of which is overriding in respect of the development and implementation of Vietnamese law.” This definition, however, is still unclear as to (i) what “the basic principles on conduct” really mean and (ii) how to determine that a statutory principle is the one having the overarching effect on the development and implementation of Vietnamese laws. 

As an illustration for this very abstract concept, Resolution 01/2014 lists out two examples which could be considered as the Statutory Fundamental Principles, including the principle of “freedom and voluntary agreement” stipulated in Article 16.4 of 2005 Civil Code (which is now replaced by Article 3.2 of 2015 Civil Code) and that of “the arbitrator must be independent, objective and impartial” under Article 4.2 of 2010 CAL.

Apart from the examples above, the Vietnamese laws have not offered any further guidance on this issue until now. Therefore, in practice, the determination of what regulations or statutory principles can constitute the fundamental ones of Vietnamese laws will heavily depend on the personal viewpoint of judges, which may be varied on a case-by-case basis.

Practical cases show that Vietnamese courts have tendency to consider the following as the fundamental principles of Vietnamese laws:

(i) The principle on free and voluntary agreement of parties (or Nguyên tắc về quyền tự do và tự nguyện thỏa thuận của các bên in Vietnamese)^[4];
(ii) The principle on equal treatment and protection by laws (Nguyên tắc bình đẳng và không bị phân biệt đối xử in Vietnamese)^[5]; and
(iii) The principle about arbitrators must be independent, objective and impartial and shall observe the laws (or Nguyên tắc trọng tài viên độc lập, khách quan và tuân theo quy định của pháp luật in Vietnamese).^[6]

From a comparative perspective, in the context of award annulment, the Statutory Fundamental Principle under 2010 CAL is in nature similar to the “public policy” doctrine as enshrined the Model Law and 1958 New York Convention on Recognition and Enforcement of Foreign Awards (“New York Convention”).^[7] However, key differences should be duly noted regarding the interpretation and application of this ground in Vietnam:

(i) First, while under Article 34.2 of the Model Law, the competent court is not mandatorily required by the Model Law to annul the award even where one of these grounds applies^[8], the wordings of Article 68 of 2010 CAL imply that Vietnamese courts must annul the award if they find such award violates the Statutory Fundamental Principles.
(ii) Second, Vietnamese courts construe the concept of the Statutory Fundamental Principles quite broadly for the award annulment.

In many countries such as Singapore, the US or France, the concept of “public policy” for award annulment is constructed “extremely narrowed”.^[9] For instance, in Eastern Associated Coal Corp. v. United Mine Workers of Am., the US court opined that “the public policy must be explicit, well defined, and dominant, and must be ascertained by reference to laws and legal precedents and not from general considerations of supposed public interest”.^[10] Accordingly, not every violation of a mandatory provision of national amounts to a violation of public policy; only provisions of laws that are fundamental to the legal order or basic morality of a state are grounds for a public policy violation.^[11]

Meanwhile, in Vietnam practical cases show that local courts normally apply a quite “loose” standard in interpreting and applying this statutory ground in the way that any violation against any mandatory regulation could be deemed as the violation to the Statutory Fundamental Principle. For example, in Decision No. 1768/QĐ-PQTT dated 6 October 2020 and Decision 12/2023/QD-PQTT dated 4 July 2023, Ho Chi Minh People’s Court and Hanoi People’s Court respectively concluded that the failure to legalize (foreign) documents during the arbitration proceedings constituted a violation against the Statutory Fundamental Principle. Notably, in certain cases, local courts dig into the merits of the dispute and re-assessed the accuracy in the reasonings and law application of the tribunal to conclude the tribunal is partial or fails to observe the laws, violating the fundamental principle of Vietnamese law as regulated in Article 4.2 of 2010 CAL.^[12]

While the definition of the Statutory Fundamental Principle is very ambiguous, the interpretation of local courts about this concept is quite broad. These create conditions for award debtors to abuse this basis to ask for the award annulment, negatively impacting upon the finality of the award and efficiency of the dispute resolution via arbitration.  

To enhance the predictability and consistence in the annulment of awards based upon the ground of violating the Statutory Fundamental Principle, some suggest that it is necessary to provide with clearer guidance on this concept or to clearly list out legal principles being the fundamental ones instead of vesting too broad authority in the courts.^[13] While agreeing that a further guidance on this concept is both legally and practically required, the authors believe that the mere provision of a clear definition of “Statutory Fundamental Principle” or a list of the fundamental principles of Vietnam may be insufficient to create any sea change for the award annulment reality in Vietnam if the local courts continue to accept a “loose” standard in interpreting and applying this legal ground for award annulment.

The authors share the view that (i) once parties have contracted to have an arbitrator resolve their disputes, it is the arbitrator’s view of the facts and of the meaning of the contract that they have agreed to accept^[14] and (ii) by agreeing to arbitrate the court should understand that the parties gain the benefits of arbitration, but sacrifice some of the benefits of the litigation including a full appeal process^[15]. Therefore, the local courts need to take a pro-arbitration approach, narrow down the concept of the Statutory Fundamental Principle and apply higher standards when considering the award-annulment request based upon this legal ground.

(b) Thoughtlessness of statutory requirements for award annulment

Pursuant to Article 14.2.dd of Resolution 01/2014, three following statutory requirements must be satisfied in order for the courts to annul a (domestic) arbitral award on the ground of violating the Statutory Fundamental Principle:

• The competent court must identify the particular Statutory Fundamental Principle in the award that was violated by the tribunal.
• Such violated Statutory Fundamental Principle must relate to the resolution of the dispute.
• Such violation must severely infringe upon the interests of the government, the legitimate rights and interests of the parties or third parties.

Accordingly, other than pointing out the specific Statutory Fundamental Principle in the award that was not respected by the tribunal, the competent court is required by law to assess whether or not such violation of the award severely infringes up the interests of the State, the legitimate rights and interests of the parties or third parties.

The current laws of Vietnam, however, do not offer any further guidance or specific criteria to determine when and how such violation can be considered having severely infringed upon the interests of the State, the legitimate rights and interests of the parties or third parties. Therefore, the assessment totally falls upon the personal discretion of the judges. According to published cases, Vietnamese courts rarely deliberate the seriousness of the violation of Statutory Fundamental Principle when setting aside awards. Instead, they concentrate on pointing out which Statutory Fundamental Principle that was not respect by the tribunal only.^[16] This once again indicates that the Vietnamese courts apply a low threshold in interpreting and applying this statutory ground for the award annulment.

(c) Unclear proof burden of the requesting party

Unlike other award-annulment grounds (i.e., those under Articles 68.2.a, b, c and d of 2010 CAL) where the burden of proof is expressly put upon the shoulders of the party requesting for the award annulment,^[17] 2010 CAL is not crystally clear about the proof burden of the requesting party in the context of the award annulment due to violation against the Statutory Fundamental Principles.

More specifically, pursuant to Article 68.3.a of 2010 CAL the party asking for award annulment is obligated to prove that the arbitral tribunal has violated one of the grounds under Articles 68.2.a, b, c and d of 2010 CAL. However, regarding the award annulment for violating against the Statutory Fundamental Principle, Article 68.3.b of 2010 CAL mentions about the responsibility of the court itself in collecting and verifying evidence only and keep silent about the burden of proof of the requesting party in this case. Thus, one of the concerns here is that whether the requesting party has any burden of proof when it relies on this ground for award annulment?

Based upon the wordings of Article 68.3 of 2010 CAL, one may argue that the burden of proof of the party seeking for the award annulment only exists when such party relies on the grounds under Articles 68.2.a, b, c and d. For setting aside the award due to violation against the Statutory Fundamental Principle, 2010 CAL does not require the requesting party to do so. Instead, under Article 68.3.b, the onus of proof in such case by law belongs to the competent courts. 

However, the above argument seems to be legally incorrect and unconvincing because of the following main reasons:

• First, pursuant to Article 69.1 of 2010 CAL, “A party with sufficient evidence proving that an award violates against the fundamental principle of Vietnamese law shall have the right, within 30 days from the date of receipt of such award, to lodge a petition with the competent (provincial) court to set aside the award. A petition requesting an arbitral award be set aside must be accompanied by materials and evidence proving that such petition has [sufficient] grounds and is lawful.” Reading this regulation together with Article 68 of 2010 CAL, it appears that the requesting party has the obligation to prove for its award-annulment request regardless of the ground based upon which such request is made.
• Second, under Article 414.3 of 2015 Civil Procedure Code (“2015 CPC”), the request for annulling an arbitral award is classified as one of civil matters (việc dân sự in Vietnamese) falling under the authority of the court, meaning that 2015 CPC shall be applied to the court proceedings in terms of considering and resolving such award-annulment request. Accordingly, Artilce 6.1 of 2015 CPC regulates that “Concerned parties have the right and obligation to proactively collect and deliver evidence to the court and to prove that their claim is well grounded and lawful.” Thus, assumed that 2010 CAL keeps silent about the burden of proof of the requesting party when it asks for an award annulment on the ground of violating the fundamental principles of Vietnamese laws, the requesting party is still obligated to do so under Article 6 of 2015 CPC.
• Also, in practice, there are several cases where the court rejected the request of the requesting party because such party fails to prove that the award violates against the Statutory Fundamental Principle.^[18]

Article 68.3.b of 2010 CAL on the court’s responsibility in collecting and verifying the evidences is seemingly aimed at clarifying the court’s responsibility in protecting “natural justice” and “public interests” being infringed by an unjust award.^[19] However, its wordings when reading together Article 68.3.a of 2010 CAL on the requesting party’s burden of proof are quite confused and could be abused to shift the proof responsibility onto the court. For instance, in Decision No. 04/2020/QĐ-PQTT dated 29 May 2020 of People’s Court of Hanoi, the requesting party simply stated that the arbitral award violates the Statutory Fundamental Principle” without providing any further explanation/evidences. The court itself then had to do all other work to determine the Statutory Fundamental Principle violated by the arbitral tribunal before annulling the award.^[20]

Therefore, from the authors’ perspective, Article 68.3 of 2010 CAL should be amended so as to make clear about the burden of proof of the requesting party when it asks for the award annulment due to a violation against the Statutory Fundamental Principle.

(d) Expansive judicial review

No review on the merits of the dispute when considering the request for setting aside an award is one of the corner-stones of the dispute resolution via arbitration. This principle is aimed to limit the excessive intervention of the courts in the arbitration process, thereby ensuring the finality of the award and the effectiveness of this dispute resolution method.

In Vietnam, though this no-merit-review rule is regulated Article 71.4 of 2010 CAL as well as Article 15.2 of Resolution 01/2014, there has been no clear and official guidance about the rule until now. Therefore, (i) what issues can be considered as those regarding the merits of the dispute and/or (ii) under what circumstance the competent court is considered as having “retried/reviewed” the merits of the dispute (xét xử lại/xét lại nội dung vụ việc) are the key questions, but yet to be clearly answered in practice.

(i) What issues can be considered as the merits of the dispute under the laws of Vietnam?

According to the Black’s Law dictionary, in contrast to procedural issues, the “merits” of a case means “The element or grounds of a claim or defence; the substantive considerations to be taken into account in deciding a case, as opposed to extraneous or technical points, esp. of procedure”.^[21]

Legislatively, the current laws of Vietnam are silent on the definition of “issues pertaining to the merits”. However, practical cases revealed that the following issues will be considered as those on “the merits of the disputes” that the court is not allowed to revisit:

• Under Decision No. 09/2020/QĐ-PQTT dated 16 September 2020^[22] and Decision No. 1064/2021/QĐ-PQTT dated 25 October 2021, Hanoi People’s Court opined that the consideration and assessment of the evidences and facts of the disputes are the issues regarding the merits of the dispute.
• Pursuant to Decision No. 1160/2021/QĐ-PQTT dated 24 November 2021, Ho Chi Minh People’s Court took the view that the tribunal’s consideration about the rights and the obligations of the disputing parties are the issues in terms of the merits of the dispute.
• In its Decision No. 141/2021/QĐ-PQTT dated 3 September 2020^[23], according to Ho Chi Minh People’s Court, the consideration of the provided evidences, the interpretation and application of the laws and the allocation of legal fees and granting relief are the issues on the merits of the dispute which has been resolved by the tribunal so the court will not review them. A similar view was also shared by Ho Chi Minh People’s Court in its Decision No. 251/2019/QĐ-PQTT dated 19 March 2019^[24], Decision No. 1420/2019/QĐ-PQTT dated 16 October 2019^[25] and by Hanoi People’s Court in its Decision No. 16/2023/QĐ-PQTT dated 27 November 2023.^[26]

In short, upon the cases above, in the context of setting aside an award, the merits of the dispute will likely include (i) claims or counterclaims of the disputing parties, (ii) the facts, evidences provided by the parties and their argument thereof and (iii) the consideration, analysis, assessment of the tribunal about (i) and (ii).

(ii) When will the court be deemed violated against the no-merit-review rule?

Under the court appeal proceedings (thủ tục xét xử phúc thẩm in Vietnamese), the appellate court is legally permitted to re-evaluate evidences provided by the parties, re-examine the correctness of the decision of the first-instance court in its judgement, change the decisions of the lower court and/or impose a different decision upon the disputing parties.^[27]

The courts, however, are not allowed by law to do so when considering the request for an award annulment.^[28] Accordingly, pursuant to Article 15.2 of Resolution 01/2014, the courts are only permitted to examine the award to determine whether there is any Statutory Fundamental Principle being violated by the tribunal in an award or not before deciding to annul or not annul such award.

As the current law of Vietnam neither defines what “retrial” or “review” (xét xử lại/xét lại in Vietnamese) really means nor offers any guidance on what action of the court can be considered as “reviewing” the dispute merits in the context of (domestic) award annulment, the determination of the court’s violation against this rule is not an easy task in practice.

Generally, the authors opine that the courts can be deemed having violated the no-merit-review (không xét xử lại/xét lại nội dung tranh chấp in Vietnamese) rule when they (i) re-consider, re-assesse the accuracy/correctness in the analysis, assessment and decision of the tribunal on the merit issues (as discussed above) and/or (ii) change the decisions made by the tribunal in the award and/or make a different/new decision imposed upon the parties on the merits.  

It is noted that though under 2010 CAL, merit retrial/review is expressly forbidden, the no-merit-view seems not to be strictly complied by Vietnamese courts in practice, more concretely:

• In its Decision No. 08/2019/QD-PQTT dated July 2019^[29], Hanoi People’s Court did review the merits of the dispute when it stated that “the tribunal’s rejection for K’s claim to A’s debts from IPC No. 34 to No. 38 and its acceptance to IPC No. 33 are inappropriate” and “the tribunal’s acceptance to A’s claim for additional construction costs is inconsistent with the nature of the case and the agreement of the parties in the contract […]” before concluding that the tribunal treated K – the requesting party – unfairly. Notably, in this decision, the court clearly mentioned that “Though this is the merit of the dispute that have been resolved by the tribunal, but it proved that whether the tribunal is impartial or not when resolving the dispute.”
• Similarly, in its Decision 04/2020/QD-PQTT dated 29 May 2020 Hanoi People’s Court reasoned that the evidences which the arbitral failed to collect was the one that “could change the nature of the case, significantly affect the legitimate rights and interests of Company B [i.e., the requesting party]”.^[30] The court further reasoned that the failure of the tribunal in collecting this evidence shows the lack of its impartiality and objectivity, violating the fundamental principles of Vietnam laws under Articles 4.2 and 4.3 of 2010 CAL and constitute a ground for setting aside the award. From the authors’ viewpoint, reviewing and assessing the strength and weakness of the provided evidences of the court in this case does constitute a violation against the principle of not reviewing the merits of the dispute.

Notably, the tendency to review the merits of the dispute to argue that the tribunal violates the Statutory Fundamental Principle is quite common in practice. This tendency has and is negatively impacting upon the finality of the arbitral award as well as the effectiveness of this dispute resolution method. Therefore, the Supreme People’s Court may need to have further guidance on this issue and request the lower courts to comply with this rule more strictly in practice to ensure the finality of the award as well as the efficiency of the arbitration.

(e) No Partial Annulment

Currently, 2010 CAL keeps silent on the partial annulment of an award. However, according to Article 14.2.c of Resolution 01/2014 “In principle, the court shall set aside only that part of an award which is beyond the jurisdiction of the arbitral tribunal without setting aside the whole arbitral award. […] Where it is impossible to separate the parts of the decision, the court shall set aside the [entire] arbitral award.” This means that Resolution 01/2014 does allow the competent court to partially annul an award if the to-be-annulled part can be separated from other parts of the award.

But unfornately, the partial annulment is stipulated in Article 14.2.c of Resolution 01/2014 dealing with the award-annulment ground of “the dispute is not within the jurisdiction of the arbitral tribunal” only. This implies that the partial-annulment cannot be applied to other cases including the award annulment due to violation against the Statutory Fundamental Principle.

According to the authors, to ensure the finality of the award as well as improve the effectiveness of this dispute resolution method in practice, the partial annulment mechanism should be extended to other cases instead of limiting to the case of excess of jurisdiction as regulated in Article 14.2.c of Resolution 01/2014 only.

In conclusion, reliance on the violation against the Statutory Fundamental Principle to annul awards increasingly becomes common in practice. In many instances, it is seen as a strategic maneuver by parties seeking to relitigate the dispute and delay the enforcement of arbitral awards. Over time, this trend can significantly erode trust in arbitration as a dispute resolution mechanism, consequently diminishing its effectiveness. The authors believe that a supportive and friendly approach from the court is a must to the development of the arbitration anywhere including Vietnam. Therefore, in addition to creating a better legal framework for arbitration, according to the authors, Vietnamese courts should take a more arbitration friendly approach when handling issues in connection with the arbitration including the request for award annulment to help facilitate the proliferation of the arbitration as an efficient dispute resolution method in the country.

^[1] The views and opinions expressed in this article are those of the authors and do not necessarily reflect the views and opinions of their law firm

^[2] Based upon court decisions published on the official website of People’s Supreme Court at https://congbobanan.toaan.gov.vn

^[3] 1959 Constitution, 1995 Civil Code or 1995 Commercial Law, Chapter II, 2005 Civil Code; Article 5 of 2005 Commercial Law, Article 5 of 2015 Maritime Law; Article 1 and Chapter II of 2015 Civil Procedure Code

^[4] Decision No. 578/2022/QĐ-PQTT dated 9 May 2022. https://congbobanan.toaan.gov.vn/3ta1062536t1cvn/. Accessed on 12 February 2024

^[5] Decision No. 08/2019/QĐ-PQTT dated 25 July 2019. https://hethongphapluat.com/quyet-dinh-so-08-2019-qd-pqtt-ngay-25-07-2019-cua-tand-tp-ha-noi.html; Decision No. 868/2023/QĐ-PQTT dated 05 June 2023. https://congbobanan.toaan.gov.vn/2ta1306738t1cvn/chi-tiet-ban-an. Accessed on 12 February 2024

^[6] Decision No. 52/2019/QĐ-PQTT dated 16 January 2019. https://congbobanan.toaan.gov.vn/5ta846153t1cvn/52_KTST_2019_KHONG_16012019.pdf. Accessed on 12 February 2024

^[7] Tờ trình số 10/TTr-HLGVN ngày 1 tháng 9 năm 2009 về Dự án Luật Trọng tài Thương mại 2010. https://quochoi.vn/hoatdongcuaquochoi/cackyhopquochoi/quochoikhoaXII/kyhopthusau/Pages/van-kien-tai-lieu.aspx/van-kien-tai-lieu.aspx?ItemID=1926;

Đề cương giới thiệu Luật Trọng tài Thương mại 2010 của Vụ Phổ biến, Giáo dục Pháp luật, Bộ Tư pháp. https://moj.gov.vn/dtvb/dtvbp/Lists/DsDuThao/Attachments/106/Du%20thao%20To%20trinh%20LTTTM%2021102010.doc. Accessed on 12 February 2024

^[8] Gary Born. 2021. International Commercial Arbitration (3^rd ed.). Wolters Kluwer

^[9] Id.

^[10] Eastern Associated Coal Corp. v. United Mine Workers of Am., 531 U.S. 57, 62 (2002). https://supreme.justia.com/cases/federal/us/531/57/

^[11] Supra note 8

^[12] Decision No. 08/2019/QD-PQTT dated July 2019. https://congbobanan.toaan.gov.vn/5ta319959t1cvn/ma_hoa_da_chuyen_doi.pdf; Decision 04/2020/QD-PQTT dated 29 May 2020. https://congbobanan.toaan.gov.vn/2ta521364t1cvn/chi-tiet-ban-an. Accessed 12 February 2024

^[13] The Supreme People’s Court Vietnam & International Finance Corporation – World Bank Group. (2010). Judicial Manual on Arbitration and Mediation. Thanh Nien Publishing House.  

^[14] Katherine A. Helm. (2006, November). The Expanding Scope of Judicial Review of Arbitration Awards: Where does the Buck Stop? https://www.dechert.com/content/dam/dechert%20files/knowledge/publication/2006/11/The%20Expanding%20Scope%20of%20Judicial%20Reviw%20of%20Arbitation%20Awards.pdf. Accessed on 19 April 2024.

^[15] Id.

^[16] Decision 12/2023/QD-PQTT dated 4 July 2023. https://congbobanan.toaan.gov.vn/2ta1225914t1cvn/chi-tiet-ban-an; Decision No. 04/2020/QĐ-PQTT dated 29 May 2020. https://congbobanan.toaan.gov.vn/2ta521364t1cvn/chi-tiet-ban-an. Accessed on 12 February 2024

^[17] Article 68.3.a of 2010 CAL

^[18] Decision 1160/2021/QD-PQTT dated 24 November 2021 of People’s Court of Ho Chi Minh City

^[19] Tưởng Duy Lượng. (2018, March 5). Một số vấn đề về xem xét hủy phán quyết trọng tài. Tạp chí Tòa án Nhân dân Điện tử. https://tapchitoaan.vn/mot-so-van-de-ve-xem-xet-huy-phan-quyet-trong-tai

^[20] Decision No. 04/2020/QĐ-PQTT dated 29 May 2020. https://congbobanan.toaan.gov.vn/2ta521364t1cvn/chi-tiet-ban-an. Accessed on 19 April 2024

^[21] Garner, B. A., & Black, H. C. (2009). Black’s law dictionary. 9th ed. St. Paul, MN, West.

^[22] Decision 09/2020/QD-PQTT dated 16 September 2020. https://congbobanan.toaan.gov.vn/2ta597119t1cvn/chi-tiet-ban-an. Accessed on 12 February 2024.

^[23] Decision 141/2021/QD-PQTT dated 3 September 2020. https://congbobanan.toaan.gov.vn. Accessed on 12 February 2024.

^[24] Decision 251/2019/QD-PQTT dated 19 March 2019. https://congbobanan.toaan.gov.vn/2ta322604t1cvn/chi-tiet-ban-an. Accessed on 12 February 2024.

^[25] Decision No. 1420/2019/QĐ-PQTT dated 16 October 2019. https://congbobanan.toaan.gov.vn/2ta477440t1cvn/chi-tiet-ban-an. Accessed on 19 April 2024

^[26] Decision 16/2023/QD-PQTT dated 27 November 2023. https://congbobanan.toaan.gov.vn/2ta1406438t1cvn/chi-tiet-ban-an. Accessed on 19 April 2024

^[27] Articles 293, 308 and 313 of 2015 CPC

^[28] Article 71.4 of 2010 CAL

^[29] Decision No. 08/2019/QD-PQTT dated July 2019. https://congbobanan.toaan.gov.vn/5ta319959t1cvn/ma_hoa_da_chuyen_doi.pdf. Accessed 12 February 2024

^[30] Decision 04/2020/QD-PQTT dated 29 May 2020. https://congbobanan.toaan.gov.vn/2ta521364t1cvn/chi-tiet-ban-an. Accessed 12 February 2024