Will the Winds of Change on Internal Appellate Proceedings In Arbitration Reach Asia? - Part 2

Abstract

This article discusses the tensions between the desire for swift and final decisions in arbitration and the desire of parties to seek redress for erroneous decisions. A result of this is the increasing adoption by international arbitral institutions of internal mechanisms of appellate review. Part 1, which was published in the April 2015 issue, introduced the internal review process of the European Court of Arbitration and discussed the contrasting lack of such processes under Asian commercial arbitration rules. This Part discusses internal review processes under the rules of a number of other international arbitral institutions.