...an interpretation of the old law— the Foreign Awards Act, 1961. Before the enactment of the Arbitration & Conciliation Act, 1996, the enforcement of domestic and foreign awards was regulated...
...a broad interpretation of the word “tribunal” in §1782(a) would create a conflict with the Federal Arbitration Act (FAA). The FAA offers narrower discovery rights in domestic arbitrations compared to...
...the Tribunal may consider […] the domestic law of a Party as a matter of fact […] follow[ing] the prevailing interpretation given to the domestic law by the courts or...
...Appeal dealt with a request for an anti-suit injunction. Interpreting Section 11 of Singapore’s International Arbitration Act 1994 (“IAA”)[4] to include both, domestic public policy and foreign public policy, it...
...provide “overlapping coverage” over non-domestic arbitral awards rendered in the United States, to the extent the two chapters do not conflict. Some courts interpreting this “overlapping coverage” have taken it...
...of ICSID arbitration. In particular, the Convention provides a unique set of rules, embodied in Articles 53 to 55, concerning the enforcement of ICSID awards. Domestic courts have encountered difficulties...
...court’s ruling.[9] THE SECOND CIRCUIT IN WEISS Weiss concerned a domestic arbitration where Weiss sued a lender who called her multiple times a day to collect outstanding debt. When proceedings...
...it restricted the free movement of goods, a conflict arose between European human rights law and European Union law. In domestic legal orders, problems of this kind are resolved in...
...neutrality and objectivity in international arbitration. While the decision may be seen as a protective measure for domestic parties, it raises critical questions about the future of international arbitration. The...
...with matters pertaining to Commonwealth law. Australia has separate legislation for domestic and international arbitrations. Australia’s domestic arbitration legislation is patterned on the Model Uniform Legislation, which, in turn, is...
...of individuals with the legal expertise necessary to support an effective system of arbitration. In addition, each of these States has had long-standing problems with the slowness of domestic court...
...which domestic and international arbitrations are submitted to different rules). As a result, the grounds for challenge of awards are different depending on whether the award subject to review is...
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