International commercial arbitration is founded on party autonomy, yet “public policy” remains a central tool of state supervision and a recurrent ground for refusing recognition or enforcement of arbitral awards. This study offers a comparative analysis of how Iran and England interpret this complex exception. In Iranian law, public policy is closely linked to “good morals” and mandatory Shari‘a-based rules, which has traditionally produced a strict legislative and judicial approach. However, recent decisions of the Tehran Commercial Courts show a growing inclination toward a narrow interpretation and a clearer distinction between domestic and international public policy, aiming to harmonize national practice with international standards. In contrast, the English legal system—relying on the New York Convention and the Arbitration Act 1996—adopts a minimal-intervention, pro-enforcement stance. English courts differentiate between domestic and international public policy and deny enforcement only in cases of manifest violations of fundamental justice or proven fraud. The comparative findings indicate that, despite distinct doctrinal foundations, both systems are gradually converging toward restricting judicial interference and embracing the notion of “transnational public policy” to enhance predictability, finality, and the enforceability of international arbitral awards.