…contains the domestication of the Convention on the Recognition and Enforcement of Arbitral Awards (the New York Convention) in Nigeria, and the Third contains the Arbitration Proceedings Rules. Legitimation of…
…[2023] SGHC 1 CTC the Singapore International Commercial Court observed that in memorial style arbitrations “any reference to ‘pleadings’ is no more than a convenient analogy, when lawyers from common…
…grounds for vacatur of an arbitral award governed by the New York Convention are limited to those set out in Article V of the Convention. A three-judge bench in the…
…states to walk a tight rope, trying to comply with conflicting norms of EU law and treaties such as the ICSID Convention. Encouraged by the European Commission, some states reacted…
…on August 13, 1999. Further, Türkiye is a party to all of the key international arbitration conventions, including the New York Convention on the Recognition and Enforcement of Foreign Arbitral…
…New York Convention, as such procedure does not fall within the framework of the New York Convention. In other words, the New York Convention does not seem to leave room…
…to public policy to enforce the award.” This provision mirrors Article V(2)(b) of the New York Convention 1958 and section 103(3) of the English Arbitration Act 1996. It is notoriously…
…of law in international affairs. Hence, he wrote that President was entitled to terminate the Treaty based on international law principles codified in the Vienna Convention on the Law of…
…She mentioned that the New York Convention provides limited grounds for challenging arbitral awards, including awards being contrary to public policy. She then explained that there was a successful attempt…
…of the arbitration agreement, Singapore courts will give effect to that law. Where there is no express choice of law governing the arbitration agreement, Singapore courts look to determine the…
…courts will react to blockchain-based awards in AI-related disputes. Considering the New York Convention, Hay outlined challenges in: (i) identifying an arbitral seat; (ii) lack of reasoning in self-enforceable awards;…
…seat of arbitration: passing laws enabling arbitration to take place; welcoming foreign arbitration practitioners into Singapore and learning from them to help to build an arbitration community in Singapore; and…
…also had certain limitations. Impact of Singapore International Commercial Court on Arbitration Next, Kevin Nash addressed whether and how the establishment of the SICC in Singapore impacted the Singapore International…
…London Court of International Arbitration (LCIA) and Singapore International Arbitration Centre (SIAC). Lindy Patterson KC stated that the Dubai International Arbitration Centre (DIAC), despite some recent challenges, is resourcing up…
…Singapore’s rise was a result of the growth of international arbitration overall and resulted from a move away from litigation. He agreed that one of the reasons for Singapore’s growth…
…such as Hong Kong and Singapore; the predominant reason for this shift being international sanctions. The UK sanctions regime is engaged where the dispute involves individuals, law firms, institutions based…
…that Saudi Arabia is a party to the major international treaties including the New York Convention and the Singapore Convention. He also added that model contracts, and especially the model…
…the country where the claimant was based and also the place of enforcement; however, the award arose from a Singapore-seated arbitration, and the laws of Singapore governed the dispute. Ms…
…(EU), and other States, have included in their new IIAs to try to curb abusive practices. For example, some recent EU treaties such as the CETA, the EU-Singapore Investment Protection…
…scenarios for the applicability of countermeasures to protect investors’ rights. The first is in proceedings under ICSID. Russia is a signatory but not a party to the ICSID Convention, and…
…to ISDS by renegotiating IIAS and enforcing national anti-ISDS policies. Notably, Venezuela denounced the ICSID Convention in 2012, the EU banned intra-EU investment disputes in 2021, and when discussing the…
…cryptocurrencies meet the requirements of investment under Article 25 of ICSID Convention? Given the delocalized nature of cryptocurrency assets, how can an investment treaty tribunal establish jurisdiction under bilateral investment…
…King’s Counsel in the U.K. and Senior Counsel in Singapore, shall be given preference over others while considering their applications. The Rules do not explain the rationale behind this. Therefore,…
…ICSID Additional Facility rules is subject to the enforcement regime of the New York Convention. When examining a jurisdictional objection thereunder, the enforcement court must establish on what basis did…
