Political risk has a key role to play in mining disputes – whether it be the catalyst, or trigger, for the dispute, or a risk materializing at some later point in time that may, for example, impact a party’s attempt to resolve the dispute. This article analyses political risk through the following lens: while some jurisdictions may inherently be riskier than others, recent disputes demonstrate that political risk can, and indeed will inevitably continue to, rear its head in the mining landscape across the world. This is evident from three current and prominent mining disputes in Panama, Australia and Ecuador which are discussed in this article, including the role played by political risk in each. Each of these disputes demonstrates the need for, and nuances associated with, understanding, responding to and successfully resolving such disputes – with as little disruption as possible to the underlying project or asset. Mining, Mining disputes, Political risk, Resource nationalism, International arbitration, Panama, Australia, Ecuador
{"title":"Political Risk and Its Key Role in Mining Disputes Around the World","authors":"Harry Burnett, Peter Brabant","doi":"10.54648/joia2023023","DOIUrl":"https://doi.org/10.54648/joia2023023","url":null,"abstract":"Political risk has a key role to play in mining disputes – whether it be the catalyst, or trigger, for the dispute, or a risk materializing at some later point in time that may, for example, impact a party’s attempt to resolve the dispute. This article analyses political risk through the following lens: while some jurisdictions may inherently be riskier than others, recent disputes demonstrate that political risk can, and indeed will inevitably continue to, rear its head in the mining landscape across the world. This is evident from three current and prominent mining disputes in Panama, Australia and Ecuador which are discussed in this article, including the role played by political risk in each. Each of these disputes demonstrates the need for, and nuances associated with, understanding, responding to and successfully resolving such disputes – with as little disruption as possible to the underlying project or asset.\u0000Mining, Mining disputes, Political risk, Resource nationalism, International arbitration, Panama, Australia, Ecuador","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":"39 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135762555","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Is the judicial assistance intended for the benefit of ‘foreign or international tribunals’ under 28 USC § 1782 available for private arbitral tribunals? The Supreme Court of the United States says it is not because that assistance is intended only for tribunals vested with governmental authority and private arbitral tribunals lack such authority. This strained reading of section 1782 appears to have been reached to achieve policy objectives, not through rigorous analysis of the statutory provision itself. Although the end the Court sought to achieve is not without merit, the means chosen by the Court to achieve the same will give rise to, among others, the unintended consequence of curtailing international commercial arbitration in contravention of the federal policy favouring arbitration. This is so because the Court ignored the root cause of the problem it sought to solve, namely that section 1782 is available to ‘any interested person’ who is not required to be before any tribunal at all. Instead of trying to solve one problem with the wrong solution, the Court should have closed or Congress should close the loophole in section 1782 so that it may properly function and provide the judicial assistance as originally intended by Congress. Arbitration, arbitral tribunal, discovery, 28 USC § 1782, Hague Evidence Convention, Intel v. AMD, Intel factors
{"title":"ZF Auto. v. Luxshare: Supreme Court’s Withdrawal of Judicial Assistance for Discovery from Private Arbitration","authors":"Janghwan Chung","doi":"10.54648/joia2023025","DOIUrl":"https://doi.org/10.54648/joia2023025","url":null,"abstract":"Is the judicial assistance intended for the benefit of ‘foreign or international tribunals’ under 28 USC § 1782 available for private arbitral tribunals? The Supreme Court of the United States says it is not because that assistance is intended only for tribunals vested with governmental authority and private arbitral tribunals lack such authority. This strained reading of section 1782 appears to have been reached to achieve policy objectives, not through rigorous analysis of the statutory provision itself. Although the end the Court sought to achieve is not without merit, the means chosen by the Court to achieve the same will give rise to, among others, the unintended consequence of curtailing international commercial arbitration in contravention of the federal policy favouring arbitration. This is so because the Court ignored the root cause of the problem it sought to solve, namely that section 1782 is available to ‘any interested person’ who is not required to be before any tribunal at all. Instead of trying to solve one problem with the wrong solution, the Court should have closed or Congress should close the loophole in section 1782 so that it may properly function and provide the judicial assistance as originally intended by Congress.\u0000Arbitration, arbitral tribunal, discovery, 28 USC § 1782, Hague Evidence Convention, Intel v. AMD, Intel factors","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":"26 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135762552","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The development and release of Large Language Models (LLM) (most famously, Chat(GPT) in the past year have sparked new conversations about the limits of Artificial Intelligence (AI). This article explores the exciting possibilities of using AI as arbitrators in maritime disputes, including an examination of the benefits, challenges, and areas for further development to facilitate its use. maritime, shipping, arbitration, artificial intelligence, ChatGPT, tech, ex aequo et bono, access to justice, expedite, replacement of arbitrator
{"title":"A New Era of Maritime Arbitration: Ex Machina Determinations","authors":"Kevin Chan","doi":"10.54648/joia2023022","DOIUrl":"https://doi.org/10.54648/joia2023022","url":null,"abstract":"The development and release of Large Language Models (LLM) (most famously, Chat(GPT) in the past year have sparked new conversations about the limits of Artificial Intelligence (AI). This article explores the exciting possibilities of using AI as arbitrators in maritime disputes, including an examination of the benefits, challenges, and areas for further development to facilitate its use.\u0000maritime, shipping, arbitration, artificial intelligence, ChatGPT, tech, ex aequo et bono, access to justice, expedite, replacement of arbitrator","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":"24 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135762559","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Russia’s illegal full-scale invasion of Ukraine in February 2022 and the resulting war have had profound humanitarian and economic consequences affecting the lives of people in Ukraine and the region’s economic stability. The international community imposed unprecedented economic sanctions on Russian entities and individuals to condemn Russia’s actions in Ukraine. As expected, Russia retaliated and issued a series of counter-measures targeting foreign investors within Russia and occupied territories in Ukraine. Such measures will give, and have already given rise to claims by foreign investors in Russia for breaches of international investment law. This article analyses the restrictive measures targeting foreign investment imposed by Russia in response to international sanctions. It further discusses their legal implications for foreign investors. An overview of investment protections afforded under international investment treaties and international conventions as potential sources of redress for foreign investors follows in section 3. The final section highlights the challenges of pursuing investment treaty claims against Russia in the current geopolitical context (section 4). investment treaty arbitration, sanctions, counter-sanctions, investment protection in Russia, Ukraine, foreign investors, expropriation, fair and equitable treatment, narrowly worded arbitration clause, nationalization
{"title":"Arbitrating Investment Disputes in Time of Geopolitical Unrest: Focus on Investment Protection in Russia","authors":"Larina Mokaled","doi":"10.54648/joia2023024","DOIUrl":"https://doi.org/10.54648/joia2023024","url":null,"abstract":"Russia’s illegal full-scale invasion of Ukraine in February 2022 and the resulting war have had profound humanitarian and economic consequences affecting the lives of people in Ukraine and the region’s economic stability. The international community imposed unprecedented economic sanctions on Russian entities and individuals to condemn Russia’s actions in Ukraine. As expected, Russia retaliated and issued a series of counter-measures targeting foreign investors within Russia and occupied territories in Ukraine. Such measures will give, and have already given rise to claims by foreign investors in Russia for breaches of international investment law. This article analyses the restrictive measures targeting foreign investment imposed by Russia in response to international sanctions. It further discusses their legal implications for foreign investors. An overview of investment protections afforded under international investment treaties and international conventions as potential sources of redress for foreign investors follows in section 3. The final section highlights the challenges of pursuing investment treaty claims against Russia in the current geopolitical context (section 4).\u0000investment treaty arbitration, sanctions, counter-sanctions, investment protection in Russia, Ukraine, foreign investors, expropriation, fair and equitable treatment, narrowly worded arbitration clause, nationalization","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":"37 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135762560","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
With China increasingly opening up in relation to trade, the number of overseas arbitration institutions practicing in China’s free trade zones is expected to rise. At the same time, however, the validity of arbitration agreements remains uncertain under Chinese arbitration law, with arbitration clauses which tend to permit administration only by domestic arbitration commissions. Chinese arbitration legislation and recent cases demonstrate that this issue can be attributed to difficulties identifying a designated arbitration commission or tribunal, as well as unclear standards to determine the nationality of the arbitration award. Considering relevant decisions of Chinese courts over the past twenty years, this article concludes that the attitude of the Chinese judiciary towards arbitration by overseas arbitration institutions in China has shifted from conservative to more open. However, a number of issues, including confusion around the arbitration jurisdiction (caused by absence of a requirement to specify the arbitration institution) make this area a difficult one for practitioners. overseas arbitration institutions, the validity of arbitration agreement, free trade zone, the seat of arbitration, the New York Convention
{"title":"The Validity of Arbitration Agreements Providing for Arbitration in Mainland China Administered by Overseas Arbitration Institutions","authors":"Qianwen Zhang, Jiani Li","doi":"10.54648/joia2023026","DOIUrl":"https://doi.org/10.54648/joia2023026","url":null,"abstract":"With China increasingly opening up in relation to trade, the number of overseas arbitration institutions practicing in China’s free trade zones is expected to rise. At the same time, however, the validity of arbitration agreements remains uncertain under Chinese arbitration law, with arbitration clauses which tend to permit administration only by domestic arbitration commissions. Chinese arbitration legislation and recent cases demonstrate that this issue can be attributed to difficulties identifying a designated arbitration commission or tribunal, as well as unclear standards to determine the nationality of the arbitration award. Considering relevant decisions of Chinese courts over the past twenty years, this article concludes that the attitude of the Chinese judiciary towards arbitration by overseas arbitration institutions in China has shifted from conservative to more open. However, a number of issues, including confusion around the arbitration jurisdiction (caused by absence of a requirement to specify the arbitration institution) make this area a difficult one for practitioners.\u0000overseas arbitration institutions, the validity of arbitration agreement, free trade zone, the seat of arbitration, the New York Convention","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":"114 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135762003","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The fight to avoid global warming of 1.5ºC above pre-industrial levels intensifies every day. The tension between organizations fighting to make this goal as real as possible and industries that still rely on fossil-based fuels and other greenhouse gas (GHG) emission systems is also growing. Since the inception of the Kyoto Protocol, many systems were put in place to attempt to save the Earth from the catastrophic consequences of global warming. One of them was the creation of carbon credits, and since they first appeared, their popularity has only increased. Together with investment in carbon credits, disputes may arise and therefore, the investor-state dispute settlement (ISDS) system may come into play. But it will not come without challenges. Carbon, Credits, Market, ISDS, Investment, Arbitration, Salini, ICSID, BIT, Kyoto
{"title":"Carbon Credits and Carbon Markets: Future Challenges for ISDS","authors":"R. P. Fleury","doi":"10.54648/joia2023020","DOIUrl":"https://doi.org/10.54648/joia2023020","url":null,"abstract":"The fight to avoid global warming of 1.5ºC above pre-industrial levels intensifies every day. The tension between organizations fighting to make this goal as real as possible and industries that still rely on fossil-based fuels and other greenhouse gas (GHG) emission systems is also growing. Since the inception of the Kyoto Protocol, many systems were put in place to attempt to save the Earth from the catastrophic consequences of global warming. One of them was the creation of carbon credits, and since they first appeared, their popularity has only increased. Together with investment in carbon credits, disputes may arise and therefore, the investor-state dispute settlement (ISDS) system may come into play. But it will not come without challenges.\u0000Carbon, Credits, Market, ISDS, Investment, Arbitration, Salini, ICSID, BIT, Kyoto","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":" ","pages":""},"PeriodicalIF":0.2,"publicationDate":"2023-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47461741","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"Book Review: The FIDIC Red Book: An International Clause-by-Clause Commentary, Christopher R. Seppälä. Kluwer Law International B.V.","authors":"Dr Nael G. Bunni","doi":"10.54648/joia2023021","DOIUrl":"https://doi.org/10.54648/joia2023021","url":null,"abstract":"","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":" ","pages":""},"PeriodicalIF":0.2,"publicationDate":"2023-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47476149","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Common law cases and commentators have debated whether the law of an autonomous arbitration agreement should be the same as the law designated in a general choice of law clause or should instead, be that of the law of the Seat. The English Law Commission is currently considering this question. This article argues that when common law courts deal with this issue within mere preliminary applications, such as for a stay of litigation, they apply an inappropriate methodology, regardless of the conclusions they come to. They are wrongly trying to impose certainty when simply faced with unclear drafting, an impossible task. In addition, most of the cases that have opined as to the law of the arbitration agreement need not have done so. The cases should have been resolved more simply under different reasoning. The article then argues that, even if the law of the arbitration agreement is important, the proper question for mere preliminary courts should often simply be, could a reasonable tribunal find validity and sufficient scope under a law it may select under the choice of law and evidentiary discretions it has? If so, the right of a putative tribunal to consider the question fully should be supported. This would then leave it to annulment or enforcement courts to review those findings if asked to do so. Even courts empowered to make pre-emptive rulings on validity and scope cannot properly do so under the methodology outlined in the leading cases. At least where contested facts could be material, such courts should not decide on these questions without an adequate hearing and without deciding either way on a case by case basis as to the particular parties’ intent. Arbitration agreement, applicable law, preliminary courts, validity and scope challenges
{"title":"‘Much Ado About … The Law of the Arbitration Agreement: Who Wants to Know and for What Legitimate Purpose?’","authors":"Jeff Waincymer","doi":"10.54648/joia2023016","DOIUrl":"https://doi.org/10.54648/joia2023016","url":null,"abstract":"Common law cases and commentators have debated whether the law of an autonomous arbitration agreement should be the same as the law designated in a general choice of law clause or should instead, be that of the law of the Seat. The English Law Commission is currently considering this question. This article argues that when common law courts deal with this issue within mere preliminary applications, such as for a stay of litigation, they apply an inappropriate methodology, regardless of the conclusions they come to. They are wrongly trying to impose certainty when simply faced with unclear drafting, an impossible task. In addition, most of the cases that have opined as to the law of the arbitration agreement need not have done so. The cases should have been resolved more simply under different reasoning.\u0000The article then argues that, even if the law of the arbitration agreement is important, the proper question for mere preliminary courts should often simply be, could a reasonable tribunal find validity and sufficient scope under a law it may select under the choice of law and evidentiary discretions it has? If so, the right of a putative tribunal to consider the question fully should be supported. This would then leave it to annulment or enforcement courts to review those findings if asked to do so.\u0000Even courts empowered to make pre-emptive rulings on validity and scope cannot properly do so under the methodology outlined in the leading cases. At least where contested facts could be material, such courts should not decide on these questions without an adequate hearing and without deciding either way on a case by case basis as to the particular parties’ intent.\u0000Arbitration agreement, applicable law, preliminary courts, validity and scope challenges","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":" ","pages":""},"PeriodicalIF":0.2,"publicationDate":"2023-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48050390","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Anti-suit injunctions are typically treated differently in common law and civil law jurisdictions. While common law jurisdictions may favour anti-suit injunctions as enforcing the parties’ agreement to arbitrate, civil law jurisdictions are generally concerned that anti-suit injunctions risk interfering with the jurisdiction of foreign court proceedings. The United Arab Emirates (UAE), where common law and civil law jurisdictions intersect, presents a unique example. The on-shore UAE courts apply civil law while the off-shore Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) Courts apply common law, bringing a new dynamic to the availability and enforcement of anti-suit injunctions. The interaction of these courts and the fine balance achieved has resulted in remarkable developments in the UAE. However, both in the UAE and further afield, certain challenging issues such as interim anti-suit injunctions, interim measures filed in parallel court proceedings, and anti-suit injunctions against third parties related to the dispute serve to test this balance. Nevertheless, with new developments in the region, a positive attitude appears to have emerged on the availability of anti-suit injunctions, opening it up to potential advancements as the jurisprudence continues to evolve. anti-suit injunctions, arbitration, foreign court proceedings, UAE, arbitration agreement, enforcement
{"title":"Anti-suit Injunctions at Crossroads: Navigating Unique Jurisdictions","authors":"A. Kurlekar, Antonia Birt, Avinash Poorooye","doi":"10.54648/joia2023018","DOIUrl":"https://doi.org/10.54648/joia2023018","url":null,"abstract":"Anti-suit injunctions are typically treated differently in common law and civil law jurisdictions. While common law jurisdictions may favour anti-suit injunctions as enforcing the parties’ agreement to arbitrate, civil law jurisdictions are generally concerned that anti-suit injunctions risk interfering with the jurisdiction of foreign court proceedings. The United Arab Emirates (UAE), where common law and civil law jurisdictions intersect, presents a unique example. The on-shore UAE courts apply civil law while the off-shore Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) Courts apply common law, bringing a new dynamic to the availability and enforcement of anti-suit injunctions. The interaction of these courts and the fine balance achieved has resulted in remarkable developments in the UAE. However, both in the UAE and further afield, certain challenging issues such as interim anti-suit injunctions, interim measures filed in parallel court proceedings, and anti-suit injunctions against third parties related to the dispute serve to test this balance. Nevertheless, with new developments in the region, a positive attitude appears to have emerged on the availability of anti-suit injunctions, opening it up to potential advancements as the jurisprudence continues to evolve.\u0000anti-suit injunctions, arbitration, foreign court proceedings, UAE, arbitration agreement, enforcement","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":" ","pages":""},"PeriodicalIF":0.2,"publicationDate":"2023-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46691027","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
By Legislative Decree no. 149/2022, Italy made several amendments to its arbitration law, which will apply to proceedings starting after 28 February 2023. The most significant innovation is the eradication of the infamous prohibition of arbitral interim measures. Indeed, the reform introduces a radically new regime on arbitral interim relief that expressly recognizes the arbitrators’ power to grant such relief and that contemplates mechanisms for challenging and enforcing arbitral interim measures (including interim measures issued abroad). This article aims to provide an in-depth analysis of the new provisions on arbitral interim relief, highlighting potential issues and solutions. In the authors’ view, despite some minor quirks, those provisions set up a very effective regime for arbitral interim relief, and are expected to contribute to making Italy a much more appealing arbitration seat internationally. Interim relief, Interim measures, Provisional measures, Italian arbitration law, Arbitration, Article 818, Emergency arbitration, Italy
{"title":"Thou Shalt Have the Power to Grant Interim Relief: The Reform of the Italian Regime on Arbitral Interim Relief","authors":"Andrea Melchionda, F. G. Santacroce","doi":"10.54648/joia2023019","DOIUrl":"https://doi.org/10.54648/joia2023019","url":null,"abstract":"By Legislative Decree no. 149/2022, Italy made several amendments to its arbitration law, which will apply to proceedings starting after 28 February 2023. The most significant innovation is the eradication of the infamous prohibition of arbitral interim measures. Indeed, the reform introduces a radically new regime on arbitral interim relief that expressly recognizes the arbitrators’ power to grant such relief and that contemplates mechanisms for challenging and enforcing arbitral interim measures (including interim measures issued abroad). This article aims to provide an in-depth analysis of the new provisions on arbitral interim relief, highlighting potential issues and solutions. In the authors’ view, despite some minor quirks, those provisions set up a very effective regime for arbitral interim relief, and are expected to contribute to making Italy a much more appealing arbitration seat internationally.\u0000Interim relief, Interim measures, Provisional measures, Italian arbitration law, Arbitration, Article 818, Emergency arbitration, Italy","PeriodicalId":43527,"journal":{"name":"Journal of International Arbitration","volume":" ","pages":""},"PeriodicalIF":0.2,"publicationDate":"2023-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48124214","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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