Abeer Sharma & Vishwas Kumar Tripathi Introduction International Arbitration (IA), which has experienced recent growth, can be described as a form of arbitration where parties opt for private international arbitrators instead of national courts. The IA is generally governed by individual state arbitral laws and global frameworks such as the UNCITRAL Model Law, and the […]
Tag: Comparative Analysis
Ahan Gadkari “The idea that the New York Convention would place the seat of the arbitration at the top of a jurisdictional hierarchy for enforcement purposes is counter to its fundamental objectives.“ – Emmanuel Gaillard I. Introduction Article V (1) of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“NYC“) is a provision […]
