…own seats. Globally, the five most preferred seats were London (43%), Singapore (31%), Hong Kong (31%), Beijing (20%) and Paris (19%). Panellists pointed out that the question was about preferences,…
…and the UN Convention on International Settlement Agreements Resulting from Mediation (more commonly known as the Singapore Convention on Mediation). The growing interest in mediation paved the way for other…
…the attraction of these seats remains. Other leading seats may follow suit to reform. For example, Singapore last month also begun consultations on the reform of its arbitration laws. One…
…The International Seabed Authority (“ISA”), established under the United Nation Convention of the Law of the Sea (“UNCLOS”) and in charge of seabed governance, is moving forward, and has signaled…
…to Singapore. He also questioned whether the present consultation process in Singapore including in particular potential reform surrounding a right to appeal on a point of law could get in…
…Article 31(1) of the Vienna Convention on the Law of Treaties (“VCLT”), which states that “[a] treaty shall be interpreted in good faith in accordance with the ordinary meaning to…
…to the “law of another country” for the purposes of the Rome Convention. In Djanogly, Mr. Justice Miles extended this ruling to limitation issues; the same analysis also applies in…
…the UNCITRAL Model Law, the New York Convention, and the ICSID Convention. Notably, the Nigerian government also aims to prevent the use of overly ambitious arbitration agreements in contracts involving…
…the scope of the New York Convention was not resolved by the appeal. Second, if the New York Convention applies to such awards, then whether Art III thereof (which contains…
…as some commentators have noted, California has struggled to persuade parties to hold their international arbitrations in California. Instead, parties have sought resolution in New York, London, Paris, Geneva, Singapore,…
…mirroring the criteria under the New York Convention. While section 42 of the 1996 English Arbitration Act already provided a mechanism to enforce provisional orders of the Tribunal in the…
In an attempt to further fortify its position as a leading arbitral institution, the Singapore International Arbitration Centre (“SIAC”) has introduced the 7th Edition of the Arbitration Rules of the…
…A decision in personam against UniCredit did raise this concern, according to EWCA. Regardless, from an international law perspective, Russian courts, as a signatory to the New York Convention (“NYC”),…
…These courts fall into three categories: Global (e.g., Singapore’s SICC), National (e.g., China’s CICC), and Hybrid (e.g., those in Gulf financial zones), each focused on supporting cross-border commerce in distinct…
…law (i.e., the Convention), the will to apply the standards set forth in the Convention where these are applicable, and to refine the balance settled by the Convention. It is…
…the exploitation of the raw materials of the deep seabed are gaining importance. Even though the United Nations Convention on the Law of the Sea (“UNCLOS”) has provided a legal…
…a reservation under Art. I(3) of the Convention to apply the Convention “only to differences arising out of legal relationships, whether contractual or not, which are considered as commercial” under…
…only does the lex loci arbitri approach produce great commercial benefits by ensuring the enforceability of the arbitral award pursuant to the New York Convention and by mitigating legal complexity…
…NY Convention to recognise arbitration awards. Recognition denotes not just a legal proceeding. It is a more generalised treatment of the finality of NY Convention awards. The NY Convention in…
…International Centre for Settlement of Investment Disputes (the “ICSID Convention”) and the New York Convention, alongside Luxembourg’s procedural rules, their complementary roles in enforcement processes are emphasized. It is furthermore…
…in respect of awards granted in states that are signatories to the New York Convention 1958. In particular, we will focus on the English Court’s power to issue worldwide freezing…
…where agreements can apply to third parties such as assignees and beneficiaries. Unlike LCIA, which requires express permission for joinder, QICCA’s provisions align more with institutions like ICC, Singapore International…
…01 December 2023 Michael Hwang, Michael Hwang Chambers LLC, ITA Reporter for Singapore In CVV v CWB [2023] SGCA(I) 9, the Singapore Court of Appeal (SGCA) upheld the Singapore International…
…the New York Convention (“NYC”), the AG first questioned whether the NYC even applies to CAS awards. According to the AG, one may conclude that mandatory arbitration does not meet…
