A Comparative Overview of Arbitration Laws: Swedish Arbitration Act 1999, English Arbitration Act 1996 and Russian Federal Law on International Commercial Arbitration 1993

摘要

As a sweeping generalization, it would be fair to say that differences in national legislation on arbitration under the various legal regimes of Sweden, England and the Russian Federation in the case of the average arbitration will not have any tangible impact on the course of the proceedings. There are three main reasons: 1. the mandatory provisions of the relevant arbitration laws are kept to a minimum; 2. the impact of primarily the UNCITRAL Model Law has promoted a high degree of homogeneity between national arbitration laws; and 3. arbitrators involved in international arbitration tend to adhere more and more to international standards of procedure rather than falling back on parochial particularities of curial law.