International commercial arbitration - enforcement of arbitral awards revisited

Abstract

International commercial arbitration is becoming increasinglyconvoluted,and hence requires a certain degree of uniformityin orderto achieve true international applicability. As a resultof this complexity, after arbitration proceedings finish both the national courts of the seat of arbitration and the national courts of enforcing jurisdiction are caught in the dilemma ofhow to interact with each other, as well as with the arbitral awards produced by arbitral tribunals. Thisarticle assesses thisphenomenon critically in order to weight current developments in arbitration against the normative structure of arbitration as they were originally intended.