Abstract

The evolution of international commercial arbitration as an alternative mechanism for the resolution of international commercial disputes has been accompanied by the gradual liberalization of national arbitration laws and the acknowledgement of the special role this institution has had to play in international trade. At present, most of the developed national arbitration laws accord substantial freedoms to parties and arbitrators in framing the arbitral procedure as they see fit and reduce the instances of possible court interference in the proceedings. These developments have been accompanied, and sometimes preceded, by the evolution of legal theories aimed at explaining the specific contractual nature of international commercial arbitration and justifying its autonomous and independent status.

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