Title: The UNCITRAL model law and Asian arbitration laws : implementation and comparisons /
Authors: Bell, Gary F.,
Year: 2018
Subjects: United Nations Commission on International Trade Law; United Nations Commission on International Trade Law; Arbitration and award Asia.; International commercial arbitration.; Law International unification; Arbitration and award; International commercial arbitration; Law International unification.; Asia
Abstract: "This book looks at how the text and the principles of the model law have been implemented (or not) in key Asian jurisdictions. Most of the jurisdictions covered in this book have declared that they have adopted the model law but often with significant modifications. Even when jurisdictions adopt some provisions of the model Law verbatim, their courts may have interpreted these provisions in a manner inconsistent with their goals and with how they are interpreted internationally. When a jurisdiction has not adopted the model law, the chapter compares its legislation to the model law to determine whether it is consistent with its principles. Each chapter follows the structure of the model law allowing the reader to easily compare the arbitration laws of different jurisdictions on each topic."--