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The UNCITRAL Model Law and Asian Arbitration Laws - Implementation and Comparisons (Paperback)
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The UNCITRAL Model Law and Asian Arbitration Laws - Implementation and Comparisons (Paperback)
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In the Asia-Pacific, thirty-eight jurisdictions have adopted the
UNCITRAL Model Law on International Commercial Arbitration. 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.
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