Conflict of Laws and Arbitral Discretion: The Closest Connection Test

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Arbitration is the dispute resolution method of choice in international commerce, but it rests on a complex legal foundation. In many international commercial contracts, the parties will choose the law governing any future disputes. However, where the parties do not choose a governing law, the prevailing approach in arbitration is to afford arbitrators broad and largely unfettered discretion to choose the law considered most appropriate or most applicable. The uncertainty resulting from this discretion potentially affects ...

Conflict of Laws and Arbitral Discretion: The Closest Connection Test 2017, Oxford University Press, Oxford

ISBN-13: 9780198787440

Hardcover

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