...be contrary to the public policy of the court’s country. The UNCITRAL Model Law on International Commercial Arbitration (the Model Law) contains a very similar provision. There is, however, no...
Search Results for : Sources Arbitration Law
...the arbitration agreement. Often difficult to identify and increasingly difficult to apprehend, the law governing the arbitration agreement (“LGAA”) has caused “extensive confusion” among commentators and practitioners of international arbitration....
Favoring Validity: The Hidden Choice of Law Rule for Arbitration ...
...law. Such pronouncements include the IBA Rules on the Taking of Evidence in International Arbitration and the UNCITRAL Model Law on International Commercial Arbitration. Various accounts have been given of...
Customary International Arbitration Law – Vol. 24 No. 2
...efficient dialogue between lawmakers from different jurisdictions needs to be engaged in so that a common ground between civil law and common law advocates can be found. *Parv Lodha...
Specific Relief in International Arbitration
...that wish to model themselves on the BAC. INTRODUCTION Since the Arbitration Law of the People’s Republic of China came into force in 1995, 183 new arbitration institutions have been...
Striving for Independence, Competence, and Fairness: A Case Study of ...
...of Arbitration Generally Applicable Law Parties Capacity of Parties Responsibility of Parties Description: Introduction Increasing recourse to international commercial arbitration as a private means of settling disputes has raised many...
The Role of Tribunals and Courts in Preserving the Rule ...
...there is no federal common law of contracts.It is accepted that the U.S. Federal Arbitration Act (“FAA”) pre-empts “anti-arbitration” state law measures taken against arbitration agreements. However, until recently, courts...
Whose Law Is It Anyway? The Contract Interpretation Problem in ...
...by ordinance. The object of the bill is to consolidate and amend the law relating to domestic arbitration, international commercial arbitration, and the enforcement of foreign arbitral awards, as well...
International Arbitration in India* – Vol. 6 No. 2
...Arbitral Code of Procedure in March of 1992,[1] and amended the Law Concerning the Arbitration Court in June of the same year.[2] Later it recommissioned the Arbitration Court and Maritime...
A Survey of Recent Legislation Concerning the Russian Arbitration Court ...
...University School of Law (2014); Hsuan Li and Jessica Tyndall, Pepperdine School of Law Class of 2014; and Matthew O’Brien, Pepperdine School of Law Class of 2015, for research support....
Reflections on the State and Future of Commercial Arbitration: Challenges, ...
...ARBITRATION LAW AND PRACTICE OF THE GERMAN DEMOCRATIC REPUBLIC BEFORE 1990 Prior to the Convention, arbitration in the GDR followed the general pattern of all East European countries, treating domestic...
The German-German Merger: Changes in Arbitration Law and Practice – ...
...fast-track arbitration provisions of the contracts, the U.S. purchaser brought an arbitration seeking to rewrite the contract or to declare the contract frustrated. Thus, although our client had only agreed...