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  • Print publication year: 2020
  • Online publication date: October 2020

25 - Divergence, Themes, and Trends in National Arbitration Laws

from Part V - Summary and Findings


This chapter acts as a capstone to Part IV’s presentation of country reports. It presents the findings of a comparative analysis of arbitration laws in the different countries reported. This analysis focuses on the different issues presented in Parts I–III, including scope and interpretation of arbitration clauses, anti-arbitration laws and policies, arbitrator bias and misconduct, the public policy exception, and other limits on arbitrability. Thus, the country reports are reviewed here to determine areas of commonality and divergences across national laws relating to judicial intervention into the arbitration process. It will also assess possible trends in international commercial arbitration.