It is well-recognized in the world of international arbitration that the curial courts—those at the seat of the arbitration—have supervisory jurisdiction over their local arbitral proceedings (the so…
In any arbitration, the parties’ choice of seat normally determines the legal regime under which an arbitration is conducted and any award is enforced. Accustomed to the international “seat standard…
In Part I of our post, we discussed the long-standing uncertainties existing in China about what legal regime governs arbitrations administered by foreign arbitral institutions. We also introduced…
