Authors: Marilyn Onukwugha & Vanessa Winkler*
Brazil-Nigeria relations are marked by centuries of commercial and cultural exchanges. For generations, the two countries have maintained an amicable relationship while promoting each other’s economic interests. Within the last decade, the nations have pledged to partner on a number of multi-billion dollar investment initiatives, such as the Brazil-Nigeria Bilateral Agriculture Development Program and the Green Imperative Program.
However, greater business opportunities between the countries augur greater numbers of disputes requiring settlement. This article addresses the prospect by examining the key elements of arbitration practice in Brazil and Nigeria. It begins by presenting the main arbitration rules governing arbitration practice in the two countries and subsequently details the procedures for the challenge, recognition, and enforcement of an arbitral award. It then discusses the two countries’ attitudes toward investment arbitration before listing their prominent arbitration institutions. Finally, it summarizes the points of comparison and contrast between arbitration practice in Brazil and Nigeria.
This article does not purport to provide an exhaustive comparison of arbitration procedures in Brazil and Nigeria. Rather, it aims to expound some of their key arbitration practices in order to give business actors and arbitration practitioners a better understanding of the rules and legislations which they will be required to abide by as Brazil-Nigeria relations escalate.
- MAIN APPLICABLE ARBITRATION RULES
Brazil’s legal system is founded on monism. As such, the Brazilian Arbitration Act (“BAA”) does not distinguish between domestic or international arbitrations held in Brazil or involving Brazilian parties. It is, however, understood that arbitrations held in Brazil are domestic and those with seats outside of Brazil are international. The BAA governs the former.
The BAA was inspired by the 1985 UNCITRAL Model Law on International Commercial Arbitration (“1985 Model Law”), though this influence is not obvious from its text. Notwithstanding considerable differences between the BAA and the 1985 Model Law, the BAA has adopted key arbitration principles such as competence-competence and the separability of the arbitration agreement.
The BAA takes a broad approach to arbitrability, establishing, for instance, that arbitration can be used to solve disputes regarding disposable patrimonial rights (Article 1, BAA). Therefore, a large variety of disputes are referred to arbitration, including disputes involving state entities.
According to the BAA, an arbitration agreement must be in writing. The agreement can be a covenant of the contract or inserted in another document that references the contract (Article 4, BAA). If the arbitration agreement does not contain relevant information to enable the commencement of the arbitral proceeding, such as the number of arbitrators, and the parties do not enter into an agreement, the claimant shall resort to the national courts for a proceeding to properly complete the arbitration agreement (Article 7, BAA). Parties also normally include a choice of forum for arbitration-related judicial support to ensure a more sophisticated arbitration-friendly jurisdiction within the country, such as São Paulo. Similarly, Article 26 of the BAA specifies the key components of an arbitral award: (i) a summary of the factual and procedural background, (ii) the grounds for the decision, (iii) the decision, (iv) the date and place of the award, and (v) the signature of the arbitrators. In general, all types of relief are permitted.
Regarding the requirements to act as arbitrator, the BAA establishes that any person who is capable of exercising civil acts and is entrusted by the parties can act as an arbitrator, provided that the arbitrator exercises impartiality and independence, competence, diligence, and discretion (Article 13, BAA). In practice, most arbitrators in Brazil are attorneys or law professors. Though there is no official code of ethics that arbitrators are obligated to follow in Brazil, parties are able to challenge arbitrators for ethical reasons by citing cases that challenge national judges pursuant to the Brazilian Code of Civil Procedure (“BCCP”). Likewise, there are no specific provisions addressing conflicts of interest for arbitrators in Brazil, although the IBA Guidelines on Conflicts of Interest in International Arbitration (“IBA Guidelines”) are usually considered in the analysis of potential conflicts of interest.
Concerning evidence gathering, it is worth mentioning that Brazil’s style of discovery differs from that of the US. The most similar feature in the BCCP is a request for production of documents, which should specify the documents that the party seeks. Even though parties and arbitrators are free to adopt the IBA Rules on the Taking of Evidence in International Arbitration to govern the taking of evidence in arbitration proceedings, this is not a widespread practice, though it has been a popular trend in international cases.
Although the BAA offers guidance on a number of stages of an arbitral proceeding, it does not require arbitral proceedings to be confidential. Regardless, parties usually include a provision on confidentiality in the arbitration agreement or terms of reference. Likewise, some institutional rules also require confidentiality.
In Nigeria, arbitration may be governed by both domestic and international sources of law depending on the nature of the case and terms of the arbitration agreement. The primary legislation governing arbitration practice in Nigeria is the Arbitration and Conciliation Act Cap. A18 LFN 2004 (“the ACA”), which mirrors the 1985 UNCITRAL Model Law. The ACA applies to both domestic and international commercial arbitrations of which the lex arbitri, or governing law, is Nigerian law. Part I of the ACA applies to domestic commercial arbitration while Part III applies to international commercial arbitration. In contrast, investment arbitrations tend to adopt international rules, such as the Washington Convention on the Settlement of Investment Disputes Between States and Nationals of Other States (1965) (“ICSID Convention”) or the 2021 Arbitration Rules of the International Chamber of Commerce (“ICC Arbitration Rules”).
Given Nigeria’s federalist system of government, states are empowered to enact legislation to regulate arbitration practice within their borders. Presently, the most prominent are the Arbitration Law of Lagos State 2009 and the Rivers State Arbitration Law 2019, which adopt the 2006 amendments to the UNCITRAL Model Law. Where disputes arise over the validity, interpretation, or scope of the arbitration agreement and the ACA or arbitration law of a Nigerian state is chosen as the governing law, then the chosen law will apply.
The ACA regiments the various stages of an arbitral proceeding. It details the requirements for an arbitration agreement and the rules applied at each stage of the proceeding, including enforcement and recognition of the arbitral award. One such requirement is that an arbitration agreement be in writing, though it may be produced through any means of communication that provides a record of the agreement (Section 1). The writing may be contained in several types of documents such as an arbitration clause in a contract, an external agreement referenced in the contract, or in exchange of points of claim or defense.
The First Schedule of the ACA consolidates arbitration rules that are to govern all arbitral proceedings unless one of the rules is found to contradict another provision of the Act (Article 1). Article 4 of the First Schedule allows party representation, though only by legal practitioners who are authorized to practice law pursuant to the Legal Practitioners Act Cap. 207 LFN 2014 (Nigeria). This may include a foreign lawyer licensed in a common law jurisdiction who obtains authorization to practice as a barrister in a particular proceeding in Nigeria. The ACA, however, does not require an arbitrator to be a legal practitioner. Though arbitrators tend to be lawyers, many Nigerian institutions encourage other professionals to participate in arbitration courses. It is also important to note that if the ACA is the lex arbitri of an international arbitration case, the parties may disregard Article 4. Where the parties select other international arbitration rules, such as the ICC Arbitration Rules, they effectively exclude the First Schedule of the ACA from their agreement.
In recent times, the consensus among arbitration enthusiasts in Nigeria is that the ACA needs reform. Proponents of this view have promoted the bills of 2018 and 2019 which seek to incorporate the 2006 UNCITRAL Model Law into the ACA. Some of the key provisions of the bills that depart from the current version of the ACA concern interim measures, emergency arbitrators, third party funding, the award review tribunal, grounds for setting aside an arbitral award, and the limitation period for enforcing an award. For example, the bills would allow a party to request an emergency arbitrator where appropriate and make an ex parte application for an interim measure. The bills also permits third party funding in arbitrations, thereby disentitling the parties to argue the applicability of the torts of champerty and maintenance. Another significant feature of the bills is their second tier tribunals, or “award review tribunals”. These new tribunals would allow the challenging party to request that an arbitral award be reviewed on the following new grounds for setting aside an award: (i) arbitrability; (ii) public policy; (iii) legal capacity; (iv) little or no due process; (v) invalid arbitration agreement; and (vi) exceeding the scope of the submission.
- CHALLENGE, RECOGNITION AND ENFORCEMENT OF ARBITRAL AWARDS
As a general rule, awards may not be appealed. However, a party may challenge an award before the state courts within a 90-day period from the notice of the award, under one of the following grounds (Article 32, BAA):
- the arbitration agreement is null and void;
- the award was rendered by someone who could not act as arbitrator;
- the award does not meet the BAA’s mandatory requirements for a valid award;
- the award exceeded the scope of the arbitration agreement;
- the award was rendered in the presence of nonfeasance, extortion, or passive corruption;
- the award was not rendered within the term established by the parties or within six months, if no other term was stipulated, from the initiation of the arbitration proceeding; or
- due process was not observed.
Challenge proceedings do not automatically stay enforcement proceedings. However, given that they are based on ordinary BCCP proceeding rules, a party may request provisional relief to stay the enforceability of the award in accordance with the requirements of periculum in mora (danger in delay) and fumus bonis iuris (likelihood of success on the merits of the case).
Only foreign arbitral awards, i.e. those rendered outside of Brazil, require recognition. Domestic arbitral awards, i.e. those rendered within Brazil, have the same status as a court judgment and are therefore enforceable regardless of recognition by a court. The Superior Court of Justice (“STJ”) is the court with jurisdiction to recognize foreign arbitral awards. It may not delve into whether the arbitral tribunal has reached an adequate decision on matters of law and facts. In order to recognize a foreign award, the applicant must only show that the award meets the established legal requirements, such as being issued by a competent authority and being final and definitive. In addition, there are some formal requirements that must be observed, such as authentication by a Brazilian consulate and sworn Portuguese translation. Brazilian law limits the grounds that can be raised by a respondent against whom recognition is sought. The grounds that may be raised can be found in Article V of the New York Convention, which are also found in similar language in Article 38 of the BAA, and, to some extent in Article 216 of the STJ Internal Rules. If the application for recognition is presented with all the required documents and no objection is raised, the recognition procedure should take between six months and a year. If an objection is raised, or there are missing documents, recognition of the award could take up to two years, depending on the complexity of the case and the STJ’s case load.
Once recognized by the STJ, the award becomes an enforceable judicial title in Brazil. After that, any party may seek enforcement with the competent federal court, which is generally the court with jurisdiction over the place where the award debtor has its place of business. The enforcement of a recognized foreign arbitral award will follow the same rules of the BCCP that apply to the enforcement of a domestic judicial decision or domestic arbitral award. Only after the award is recognized may a party start enforcement proceedings. However, it is possible to obtain provisional relief to attach assets if the creditor demonstrates the risk of non-fulfillment of the arbitration award after the recognition procedure concludes. The debtor may oppose enforcement on very limited grounds relating to technical procedural matters but may not raise questions related to the merits of the award or re-discuss the enforceability as recognized by the STJ. Brazilian courts have generally favored the recognition and enforcement of foreign awards.
In Nigeria, as in other countries, arbitral awards are final. They cannot be appealed. They can, however, be challenged and subsequently set aside. According to Section 48 of the ACA, the court may set aside the award if the challenging party successfully proves any of the following grounds:
- a party to the arbitration agreement was under some incapacity;
- the arbitration agreement is not valid under the law which the parties have indicated should be applied […or] the laws of Nigeria;
- [the challenging party] was not given proper notice of the appointment of an arbitrator or of the arbitral proceedings or was otherwise not able to present his case;
- the award deals with a dispute not contemplated by or not falling within the terms of the submission to arbitration;
- the award contains decisions on matters which are beyond the scope of submission to arbitration
- the composition of the arbitral tribunal, or the arbitral procedure, was not in accordance with the agreement of the parties, unless […] in conflict with a [non-derogable] provision of this Act;
- the composition of the arbitral tribunal or the arbitral procedure was not in accordance.
Additionally, the award may be set aside if there is misconduct by the arbitrators, including challenges to the arbitrators’ impartiality or independence. In Global Gas & Refinery Ltd v SPDC, the High Court of Lagos State (Nigeria) set aside the award after Global Gas challenged the impartiality of two arbitrators despite that the ICC Court of Arbitration had already dismissed the challenge in consideration of the IBA Guidelines.
In order to challenge the award, the party must submit an application to a state High Court or the Federal High Court within three months of the issuance of the award. This also applies to international arbitrations governed by the ACA (or Nigerian laws). Whereas the ACA does not specify the procedure for instituting a challenge in court, the Lagos State Arbitration Law stipulates that an application be made by originating motion. If the award is set aside, then the unsuccessful party loses the right to enforce the award.
According to Section 31(3) of the ACA, domestic arbitral awards may be enforced at any High Court of first instance in the manner and to the effect as any court order or judgment. The application must include the original or certified true copy of the arbitration agreement and award. Upon instituting the proceeding, the other party must be given notice and is entitled to deny recognition and/or enforcement of the award. Once enforced, the domestic award will automatically be deemed recognized.
Conversely, foreign awards may be enforced and recognized in accordance with the lex arbitri. Nigeria is a signatory to the ICSID Convention. The International Center for Settlement of Investment Disputes (Enforcement of Awards) Act, Cap I20 LFN 2004 codifies the ICSID Convention into Nigerian law and details the process for recognition and enforcement of a foreign award. Nigeria is also signatory to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”), which was codified in the ACA. The New York Convention applies to foreign awards involving international commercial arbitrations on disputes involving two signatories.
- INVESTMENT TREATMENT AND DISPUTE RESOLUTION
For mainly political reasons, such as protection of its sovereignty, Brazil has neither signed the ICSID Convention nor ratified any bilateral investment treaty (“BIT”). Despite that, Brazil has historically always attracted investments due to its strong consumer market, relatively steady democratic institutions, general pro-arbitration stance (including the possibility of having arbitral proceedings against Brazil as a sovereign state), and protection to foreign investments guaranteed by the domestic legislation. In addition, the Brazilian Constitution does not limit the protection to foreign investments and it protects private property, with no distinction between foreign or domestic property.
More recently, Brazil has concluded a few bilateral agreements called Acordos de Cooperação e Facilitação ao Investimento (Agreement for Investment Cooperation and Facilitation) (“ACFI”) with countries such as Mexico and Angola, which compare and contrast with other BITs. In fact, it is said that Brazil has created an alternative policy regarding foreign investments. For instance, the ACFIs contain Most Favored Nation provisions, which require the state party to one investment treaty to provide investors with treatment no less favorable than the treatment it provides to investors under other investment treaties or to its nationals. On the other hand, the ACFIs do not provide for Fair and Equitable Treatment and Full Protection and Security. Also, the ACFIs’ dispute resolution mechanism is focused on dispute prevention and, only in some cases, allows State-to-State Arbitration. These bilateral agreements aim to enhance foreign investments by authorizing, inter alia, facilitated foreign wire transfers, facilitated visa issuance, environmental legislation, technical regulations.
Nigeria fosters an atmosphere that is conducive to investment treaties and investor-state arbitration. It is a signatory to over fifty investment treaties and investment-related instruments, including the ICSID Convention and the African Continental Free Trade Agreement.
Most of Nigeria’s BITs contain similar provisions that detail the scope of the following standards: protected investor; protected investment; fair and equitable treatment; expropriation; national treatment; protection and security; and umbrella clauses.
Along with these standards, these BITs are comparable in terms of the similar substantive and procedural rights they guarantee. For instance, many of Nigeria’s BITs impose obligations on the Host State to provide compensation to investors who incur losses as a result of armed conflict and/or civil unrest. They also oblige the Host State to allow investors to freely transfer their investment payments as they please, pursuant to any relevant monetary policies of the contracting States. In more recent BITs to which Nigeria is a signatory, there are carve-outs, denial of benefits clauses, and non-precluded measures clauses which exclude certain claims or remedies from the investment instrument. For example, the Nigeria-Singapore BIT carves out “matters of taxation” from the scope of the treaty.
Slight contrasts between Nigeria’s BITs typically relate to cooling-off and forum selection clauses. Investors can expect to wait 60 days, 3 months, or 6 months before instituting a proceeding against the Host State, depending on which investment treaties apply. Many of Nigeria’s BITs allow the investor to select the venue in which preliminary issues, such as jurisdiction and admissibility, will be resolved. The venue options are usually ICSID, UNCITRAL ad hoc tribunals, and/or the local courts of the Host State. However, a number of Nigeria’s BITs stipulate the exact venue: e.g., the Nigeria-UK BIT expressly selects ICSID; the Nigeria-Egypt BIT allows the Regional Centre for International Commercial Arbitration’s chapters in Cairo or Lagos.
Investment treaties are not the only source of protection offered to parties to an investment agreement. The Nigerian Investment Promotion Commission (NIPC) Act 2004 protects foreign direct investments flowing into the country. The NIPC Act offers similar substantive and procedural protections to those that commonly appear in investment treaties. Section 26 recognizes arbitration as the preferred mode of dispute settlement for investment disputes. Specifically, section 26(2a) requires arbitration for investment disputes involving a Nigerian investor while Section 26(2b) requires investment disputes to be resolved in accordance with the appropriate investment treaty, if one exists. Section 25 of the Act prohibits expropriation except for matters of national interest or public purpose. Furthermore, Section 24 permits free transfer of investment payments through licensed institutions.
Between the NIPC Act and the numerous investment instruments to which Nigeria is a signatory, investors enjoy many protections in Nigeria. As investments continue to flow into the country and Nigeria continues to cultivate its pro-arbitration atmosphere, Nigeria could experience heightened popularity as an arbitration hub not just sub-regionally but globally.
- MAIN ARBITRATION INSTITUTIONS IN THE COUNTRY
Most arbitration proceedings in Brazil are domestic arbitrations, as many commercial parties perceive arbitration as a worthy alternative to the judicial system. Domestic arbitral proceedings are usually conducted under the rules of an arbitral institution. Thus, one of the consequences of the popularity of arbitration in Brazil is that there are many national arbitration institutions. There are over 100 arbitration institutions in Brazil, but only a few actually conduct a significant number of arbitrations and are very renowned in the market, such as:
- Centro de Arbitragem e Mediação da Câmara do Comércio Brazil Canadá (CAM-CCBC), in São Paulo;
- Câmara de Conciliação e Mediação e Arbitragem (CIESP-FIESP), in São Paulo;
- Câmara de Arbitragem do Mercado (CAM); in São Paulo;
- Câmara de Mediação e Arbitragem (CAMARB), in Belo Horizonte; and
- Centro Brasileiro de Mediação e Arbitragem (CBMA), in Rio de Janeiro.
In 2017, the ICC opened an office in São Paulo, thereby further enhancing Brazil’s arbitration climate.
According to the TEMPLARS Arbitration Report on Nigeria 2021, arbitral proceedings in Nigeria are usually ad hoc and governed by the ACA. Despite this, several Nigerian institutions have expanded their outreach considerably in the past few years. Based on Emilia Onyema’s 2020 Arbitration in Africa Survey Report, the most prominent arbitration institutions in Nigeria are:
- Chartered Institute of Arbitrators, Nigeria chapter;
- International Centre for Arbitration & Mediation, Abuja;
- Lagos Chamber of Commerce International Arbitration Centre;
- Lagos Court of Arbitration; and
- Nigerian Institute of Chartered Arbitrators
Although the institutions mentioned above administer arbitration cases, not all well-regarded arbitral institutions in Nigeria do. Some solely provide facilities, appoint authorities, and offer other arbitration-related services.
As observed above, there are several differences between arbitration practice in Brazil and Nigeria, such as the fact that the BAA does not distinguish between domestic and international arbitration, while the ACA ascribes different sections to them. Further, domestic and foreign awards must be recognized by the judiciary in Nigeria, whereas in Brazil this proceeding is only necessary for foreign awards. Another distinction between the two countries is that Nigeria is signatory to over fifty investment-related instruments, including the ICSID Convention, while Brazil has historically neither signed the ICSID Convention nor ratified bilateral investment treaties. Lastly, in Nigeria, ad hoc proceedings are more common than institutional proceedings, unlike in Brazil.
Despite these and other differences, there are also many similarities between the arbitration practices in both countries. The arbitration-related legislations of both countries contain similar arbitral rules largely based on the UNCITRAL Model Rules. The corresponding provisions of the BAA and the ACA include the obligation to produce a written arbitration agreement, the finality of the arbitral award, and the grounds for setting aside the award. Likewise, neither the BAA nor the ACA stipulate that an arbitrator must be a legal practitioner. Instead, both legislations impart autonomy to the parties to decide who will adjudicate their dispute, so long as the selected arbitrators uphold the principles of impartiality and independence, among others.
Whether comparing or contrasting the ways arbitration is practiced in Brazil and Nigeria, it is important for those with commercial ties to both countries to familiarize themselves with both sets of arbitration rules. The reality is that the stronger the commercial and investment ties between Brazil and Nigeria grow, the more important this legislation and these arbitration rules will become.
* Marilyn Onukwugha ‘22 is an LL.M. Graduate of Columbia Law School where she sat on the board of the Columbia International Arbitration Association as a Co-Chair of Columbia Arbitration Day. Vanessa Winkler is a Senior Associate at MAMG Advogados.
 Cynthia Egboboh, FG partners Brazil on $1.2 bn Green Imperative Program to deepen agriculture benefits in Nigeria Businessday NG (2022), https://businessday.ng/agriculture/article/fg-partners-brazil-on-1-2-bn-green-imperative-program-to-deepen-agriculture-benefits-in-nigeria/ (last visited Apr 4, 2022); see also José Romildo, Chanceler destaca papel da Nigéria na aproximação Brasil-África Agência Brasil (2022), https://agenciabrasil.ebc.com.br/internacional/noticia/2019-12/chanceler-destaca-papel-da-nigeria-na-aproximacao-brasil-africa (last visited Apr 4, 2022).
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 United Nations Commission on International Trade Law, UNCITRAL Model Law on International Commercial Arbitration(1985) (with amendments in 2006).
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 Arbitration and Conciliation Act, Cap. 18, Laws of the Federation of Nigeria (as amended) (2004).
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 Lagos State Arbitration Law, No. 18, (2009). See also Isaiah Bozimo, Martha Apeh & Christopher Awodimila, Guide to Arbitration Places (2021), https://delosdr.org/wp-content/uploads/2018/06/Delos-GAP-2nd-edn-Nigeria.pdf (last visited Apr 4, 2022).
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 Global Gas & Refinery Limited v. Shell Petroleum Development Company, Suit No. LD/1910GCM/2017 (Feb. 25, 2020) (Nig.).
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 ICSID Convention, supra note 8.
 The International Center for Settlement of Investment Disputes (Enforcement of Awards) Act, Cap I20, Laws of the Federation of Nigeria (2004).
 United Nations Conference on International Commercial Arbitration, Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958).
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