Abstract

The article delves into the complexities of determining the applicable law in international arbitration agreements. It discusses the growing role of arbitration in international trade and highlights the challenges of identifying governing laws, especially when parties have not specified them. The article also explores common law and civil law approaches to this issue and mentions Uzbekistan’s recent legislative efforts to become an arbitration-friendly jurisdiction. The text is particularly relevant for legal professionals and scholars interested in international arbitration and its evolving legal frameworks

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