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Another Award Set Aside—Excessive Jurisdiction

Parties to complex international arbitrations should take note. It is critically important to ensure that requests for relief in the written phases of the proceedings accurately capture all relief being sought. Late or...more

Party Nomination of Arbitrators: Égalité of Parties and the 'Dutco Principle'

Party Nomination of Arbitrators - Parties benefit from a broad freedom in nominating arbitrators. In the context of an arbitration seated in France, the French law principle of égalité (equality) between the parties in...more

New SIAC Rules: The Need For Refinement

Last month, the Singapore International Arbitration Centre (SIAC) started a review and revision of its 2016 Rules (the “2020 Review”). The 2016 Rules introduced a number of novel provisions to address “early dismissal of...more

The Law of an Arbitration Agreement: Is it the Law of the Seat or the Law of the Underlying Contract? – Paris Contradicts London

If there is no express law of the arbitration agreement, the law with which that agreement has its closest and most real connection is either the law of the underlying contract or the law of the seat of the arbitration. In...more

The English High Court Shuts Out “Inadequate Reasons” as a Basis to Set Aside an International Arbitration Award –...

Where London is the Seat those involved in international arbitration ought to know that challenges under Section 68 of the Arbitration Act 1996, (the “Act”) require highly exceptional conditions. We say this because Section...more

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