The International Arbitration Rulebook: A Guide to Arbitral Regimes

October 30, 2019

Co-chair of Dechert’s International Arbitration practice Arif Hyder Ali and Dechert partner Alexandre de Gramont are pleased to announce the publication of their co-authored book The International Arbitration Rulebook: A Guide to Arbitral Regimes. For many cross-border transactions and disputes, international arbitration continues to provide the only forum for dispute resolution that is acceptable to both parties. Yet it also provides a dizzying array of arbitral centers and regimes from which to choose when negotiating an arbitration agreement — and which then have to be navigated if and when a dispute arises.

The Rulebook — the first of its kind to undertake a comparative review of the different rules and approaches of major international arbitral regimes — is designed as a practical guide for practitioners (including in-house counsel) who have to draft arbitration agreements and handle arbitration disputes. The authors also anticipate that the Rulebook will be useful to arbitrators and institution staff, as well as parties and their counsel, in providing a single volume that presents a variety of different ways to approach a particular issue. The Rulebook will be useful to students, as well as lawyers who are new to the field, in understanding the variety of ways in which an international arbitration case can proceed from beginning to end. Finally, the authors hope that through its comparative approach, the Rulebook will help to advance the principal virtue of international arbitration — which is the ability of the parties to draw on different approaches from various legal systems and traditions to design bespoke procedures to resolve the dispute at hand.

The Rulebook provides a comprehensive and comparative analysis of nine of the world’s leading international arbitration regimes:

  • The American Arbitration Association/International Centre for Dispute Resolution (AAA/ICDR);
  • The China International Economic and Trade Arbitration Commission (CIETAC);
  • The Hong Kong International Arbitration Centre (HKIAC);
  • The International Court of Arbitration of the International Chamber of Commerce (ICC);
  • The International Centre for Settlement of Investment Disputes (ICSID);
  • The London Court of International Arbitration (LCIA);
  • The Arbitration Center of the Stockholm Chamber of Commerce (SCC);
  • The Singapore International Arbitration Centre (SIAC); and
  • The Arbitration Rules of the United Nations Commission on International Trade Law (UNCITRAL).

After providing a brief introduction to the different regimes, the Rulebook takes the reader through each step in the arbitral process — while explaining the approaches that the different regimes take at each such step. Detailed chapters, each accompanied by comparative charts and tables, explain the approaches of the different regimes with respect to the commencement of the arbitration; the constitution and powers of the arbitral tribunal; the initial procedural conference; the evidentiary procedure; the written and oral proceedings; costs and fees; and the form, effect, and enforceability of the arbitral award. The Rulebook also covers special procedures and procedural innovations available under the different regimes, such as expedited procedures, mediation-arbitration, consolidation and joinder of parties, interim measures of protection, emergency relief and summary procedures. Each chapter also provides practical advice based on the authors’ extensive experience in handling different types of international arbitration around the world, sitting as arbitrators and teaching international arbitration courses.

The Rulebook was published by Wolters Kluwer on October 22, 2019.  For additional details, please click here.

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