A Comparative Perspective on International Commercial Courts: Jurisdiction, Applicable Law and Enforcement of Judgments

Document Type

Book Chapter

Publication Date

4-2022

Source Publication

Brekoulakis S, Dimitropoulos G, eds. International Commercial Courts: The Future of Transnational Adjudication. Studies on International Courts and Tribunals. Cambridge University Press; 2022:115-157.

Keywords

international courts; international arbitration; jurisdiction; applicable law; foreign judgments; commercial courts; commercial arbitration

Abstract

As the international business community and their legal advisors have become more sophisticated in choosing the fora for resolving their disputes, a number of ‘international’ courts have been established to compete with arbitration in the lucrative international dispute resolution market. This chapter examines the features of these courts that have been designed in response to the perceived strengths and deficits of national courts in relation to arbitration so as to maximise those strengths and reduce those deficits for courts and improve their competitive advantages for those in need of international commercial dispute resolution services.

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