Summary: The lifeblood of international arbitration is the treatment accorded by national courts to the arbitration agreement and the award. Recently, there have been a series of cases from the courts and in particular the Supreme Court of the UK, the US and France on the scope, nature and effect of agreements to arbitrate and enforcement of annulled awards. These cases show divergences in approach in major centres of arbitration that should not be overlooked when negotiating arbitration agreements or conducting arbitration.
Thomas H. Webster
19, rue du Docteur Blanche
Paris 75016
France
Tel. (33) 971 448 546
(33) (0) 785 33 1974
e-mail: webster@thwebster.com