Divergence, Themes, and Trends in National Arbitration Laws

This chapter presents the findings of a comparative analysis of arbitration laws in fourteen countries. The analysis focuses on scope and interpretation of arbitration clauses, anti-arbitration laws and policies, arbitrator bias and misconduct, the public policy exception, and other limits on arbitrability. The chapter determines areas of commonality and divergences across national laws relating to judicial intervention into the arbitration process, and provides an assessment of possible trends in international commercial arbitration.