Law, Practice and Procedure
International commercial arbitration straddles multiple jurisdictions, national laws and judicial forums. The seat court exercises supervisory jurisdiction over the arbitration proceedings, and the law of the seat provides the procedural law governing the arbitration proceedings, including the grounds for any setting aside of the arbitral award. The court of the place of enforcement of an arbitral award determines whether an arbitral award should be enforced there based on the law of the place of enforcement. An understanding of the various laws is important at the pre-dispute stage such as when selecting the relevant arbitral seat, as well as part of a comprehensive strategy when a dispute has arisen. This toolkit offers you the ability to select jurisdictions of interest to you, provides a quick snapshot on the laws and practices relating to such arbitration proceedings, and to compare the approaches of different jurisdictions on a particular issue.