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Sign inYoung Arbitration Associations PAW event - Conflicts of Laws in International Arbitration: a Comparative Perspective
Presentation
This session will explore the question of which law governs the different acts of an arbitration.
In the Opening Scene, the panel will examine the law applicable to the arbitration agreement. With the upcoming 2025 Arbitration Act expected to reshape the English common law position, how does this compare to the French approach — and could Swiss law offer a pragmatic middle ground?
The Main Act will focus on the law governing the merits. From the interpretation and application of Section 46(3) of the Arbitration Act 1996 to the recent introduction of Article 822 in the Italian Code of Civil Procedure, the discussion will consider how tribunals navigate competing conflict of laws rules — and what happens when party autonomy meets procedural innovation.
Finally, in the Final Curtain, the discussion will turn to the role of mandatory rules and public policy in post-award proceedings — in particular, how French, Italian and Swiss courts respond when the chosen law conflicts with overriding national principles.
Guest Speakers
Cocktail
18:00 - 19:00Venue
August & Debouzy7 rue de Téhéran
75008 Paris
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