Analysing Arbitration Laws across Legal Systems
In this paper, the national Indian and Chinese statutes on arbitration are compared with the UNCITRAL Model Law. After a presentation of the GILD-MMC project, focus is especially on textual aspects indicating attitudes towards the relation between the administrative powers and the parties in commerc...
Main Authors: | , |
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Format: | Article |
Language: | deu |
Published: |
Aarhus University
2004-03-01
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Series: | Hermes |
Online Access: | https://tidsskrift.dk/her/article/view/25755 |
Summary: | In this paper, the national Indian and Chinese statutes on arbitration are compared with the UNCITRAL Model Law. After a presentation of the GILD-MMC project, focus is especially on textual aspects indicating attitudes towards the relation between the administrative powers and the parties in commercial arbitration. Thus, looking at the features all-inclusiveness, information load, information spread, legislative style and transparency signifi cant differences are found and related to the different com municative purposes (overall model vs. specifi c national rules), the different legal traditions (common law vs. civil law) and the different political systems (westernised market economy vs. socialist market economy). |
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ISSN: | 0904-1699 1903-1785 |