Comparative Law of International Arbitration
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By: Jean-François Poudret, Sébastien Besson
Guides practitioners through the international arbitration process from beginning to end. This work covers each step of arbitral procedure, from the conclusion of the arbitration agreement to the enforcement of the arbitral award, from a comparative standpoint, helping practitioners decide which jurisdiction's rules they wish to be bound by
AI Overview
The book "Comparative Law of International Arbitration" by Jean-François Poudret and Sébastien Besson is a comprehensive guide to international arbitration, offering a comparative analysis of all aspects of arbitration law. Here is a detailed overview of the book:
Key Themes
- Comparative Analysis: The book provides a comparative analysis of arbitration rules, procedures, and awards across various jurisdictions. It covers major arbitration jurisdictions, including those from UNCITRAL, UN texts, and national legislation from countries such as Sweden, Belgium, Germany, England, Italy, Holland, France, and Switzerland.
- Arbitral Procedure: It guides practitioners through each step of the arbitral procedure, from the conclusion of the arbitration agreement to the enforcement of the arbitral award. This includes detailed advice on topics such as the arbitration agreement, progressing a case, and the award and enforcement of the award.
- Strengths and Weaknesses: The book pinpoints the strengths and weaknesses of arbitration in each jurisdiction, helping practitioners decide which jurisdiction or institution's rules they wish to be bound by.
- Comprehensive Materials: It reproduces a comprehensive selection of comparative materials, including texts from UNCITRAL and UN, as well as national legislation from various countries. Additionally, it features materials on the form and content of arbitral deliberations not normally available in the public domain.
Plot Summary
The book is structured to provide intelligent and approachable guidance through the entire international commercial arbitration process. It starts by defining the subject of international arbitration and then delves into the specifics of arbitral procedures, comparing the rules and practices in different jurisdictions. The authors aim to help practitioners navigate the complexities of international arbitration by providing a detailed and comparative overview of the process.
Critical Reception
The book has received positive reviews for its comprehensive coverage and insightful analysis. Here are some excerpts from critical reviews:
- Book Review by Certilman: The review highlights that every tome has its most revealing moments, and Poudret and Besson reveal core insights into a fundamental perspective of the authors. The book is praised for its ability to provide a deep understanding of international arbitration.
- Seppälä Arbitration Book Review: The review notes that the second edition of the book is a valuable resource for practitioners, offering practical guidance and comparative analysis. It is commended for its detailed advice on various aspects of arbitration, including the arbitration agreement, case progression, and award enforcement.
Overall, "Comparative Law of International Arbitration" by Jean-François Poudret and Sébastien Besson is a seminal work in the field of international arbitration, providing practitioners with a comprehensive guide to navigate the complexities of this specialized area of law.