Abstract
Investor-state dispute settlement mechanisms embodied in most investment treaties provide rights to foreign investors to seek redress for damages arising out of alleged breaches by host governments of investmentrelated obligations. The system of investment dispute settlement has borrowed its main elements from the system of commercial arbitration despite the fact that investor-state disputes often raise public interest issues which are usually absent from international commercial arbitration. Investor-state arbitration may often call for reconciliation of public international law doctrines with the private legal principles of contract law. This hybrid source of rights is generating new questions and in particular challenges relating to the quality of awards and jurisdictional issues.
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