The paper highlights the role of domestic law in international arbitration. It addresses the crucial role of the law of the seat and of other legal systems. It then analyzes situations in which the influence of domestic law and courts can be considered pathological and then discusses how the conflicts between the different visions of arbitration can be addressed
Radicati Di Brozolo, L., The impact of National Law and Courts on International Commercial Arbitration: Mythology, Physiology, Pathology, Remedies and Trends, <<Les Cahiers de l'Arbitrage - The Paris International Arbitration Journal>>, 2011; (3): 663-692 [http://hdl.handle.net/10807/57210]
The impact of National Law and Courts on International Commercial Arbitration: Mythology, Physiology, Pathology, Remedies and Trends
Radicati Di Brozolo, Luca
2011
Abstract
The paper highlights the role of domestic law in international arbitration. It addresses the crucial role of the law of the seat and of other legal systems. It then analyzes situations in which the influence of domestic law and courts can be considered pathological and then discusses how the conflicts between the different visions of arbitration can be addressed
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