Resolution of Disputes or Issues By International Arbitration

Running head : TITLE
TITLE
Name of the Student
Name of the University
Author Note

1TITLE
Abstract
Acknowledgements
Abbreviations (if applicable)
Table of Cases (All case law – specify jurisdiction if applicable)
Table of Statutes (Legislation - specify international agreements if applicable)

2TITLE
CHAPTER 1 – INTRODUCTION
1. Background of the study
International arbitration is considered to be a process relating to resolution of disputes or issues.
With the help and assistance of the process of international arbitration, disputes and issues are
settled. The primary purpose and objective in relation to international arbitration is the provision
of a neutral and unbiased forum to the involved parties for the resolution of disputes or issues.
The process of arbitration is considered to be an alternative process or a substitute process for
dispute resolution. The aforementioned process is utilized for solving disputes in lieu of the
process of litigation. An arbitration might be optional, however, it must be mentioned that
presently, the contracts that are established in the business world, contain a mandatory clause
relating to arbitration. It means that in relation to any disputes that may arise, the process of
arbitration shall be utilized in order to settle such disputes1. This dissertation discusses the
growth and expansion regarding international arbitration in the country of Pakistan. It also
forwards a discussion in relation to the challenges regarding the implementation of the process of
arbitration and arbitral awards in the nation of Pakistan.
2. Problem statement
The reason why this research is conducted is to know the importance of the process relating to
arbitration. Regarding such process relating to arbitration, the parties that are involved must
choose and agree upon any particular individual as an arbitrator. The arbitrator shall hear the
forwarding of the involved parties and give effect to a decision accordingly. The parties that will
be involved in the dispute resolution process of arbitration, shall be bound to adhere to the
decision that may be forwarded by the arbitrator. As the globalization in relation to business and
1 Cole, Tony, and Pietro Ortolani. Understanding International Arbitration. Routledge, 2019.

3TITLE
trade have increased to a great extent after the World War II, the need or requirement regarding
the process of arbitration has also been noticed. An emergence of a process relating to arbitration
that may be utilized in order to settle and resolve disputes was noticed among several business
houses in various nations of the world. In the year of 1959, a treaty was given effect to by certain
nations in relation to arbitration purposes for the business world. The name of the treaty was
‘New York Arbitration Convention’.2 The aforementioned Convention had been accepted and
agreed upon by a quantum of one hundred and fifty four nations, who are also members to the
United Nations. A quantum of more than sixty five nations have participated in the decisions that
have been forwarded through the process of arbitration3.
The principal benefit and advantage in relation to international arbitration is the enforceability of
the process and its decision. The enforceability of litigation or the court cases in relation to the
business organizations in different nations is not guaranteed. It must be mentioned that a
particular process of arbitration is systematized on the basis of the consent of the involved parties
and the consequence regarding a particular process of arbitration is kept private and secret in all
the cases of arbitration. Other benefits or advantages regarding the process of arbitration include
speedy and swift process, time management and less expensive than court cases or litigation
processes. Hence, the process of arbitration is considered to be beneficial as compared to the
litigation processes in any particular nation4. Therefore, the focus of this study is the
international arbitration and the challenges that are faced relating to such international arbitration
in Pakistan.
2 New York Arbitration Convention, 1959.
3 Yamashita, Kenshiro, Tatsuya Emoto, and Kazuki Watanabe. "Sovereignty Immunity on International Arbitral
Awards in Asia: Based on New York Convention and Domestic Law in Asia on Sovereign
Immunity." ALSA (2017): 150.
4 Wessel, J., and B. Pilbrow. "The Roles of Psychology in International Arbitration-A Review." Transnational
Dispute Management (TDM) 15.1 (2018).

4TITLE
3. Research aims
The aim of this research report is to evaluate the challenges that are being faced by the populace
of Pakistan. This report aims to discuss the complexities regarding the implementation of the
arbitral awards in connection to the process of arbitration in the aforementioned nation.
4. Research Objectives
Objectives of the research are as follows:-
 To understand the process of arbitration in the nation of Pakistan.
 To analyse the process of arbitration in Pakistan.
 To find the challenges in relation to the process of arbitration in the nation mentioned
above.
 To provide recommendations regarding the challenges in relation to the process of
arbitration in the abovementioned nation.
5. Research Questions
The research questions designed for the studies are as follows:-
 What is the process of arbitration in the nation of Pakistan?
 How the process of arbitration is given effect to in Pakistan?
 What may be the challenges in relation to the process of arbitration in Pakistan?
 What may be the recommendations regarding the challenges that may be forwarded in
relation to the process of arbitration conducted in Pakistan?
6. Research Rationale
The domain of international arbitration is considered to be a popular practice in the field of legal
structure. There are several concerns in relation to the functionality of the process of
international arbitration. For instance, a dispute has arisen between two business organizations

5TITLE
belonging to two distinct nations. In such a situation, concerns and issues arise in relation to the
jurisdiction of the court and the selection of the law. Both the nations may demand that the
matter should be settled in their own respective court and their own respective law should be
followed. Hence, the presence of a process that provides a neutral forum that may be accepted
and agreed upon by the involved parties, helps to settle and resolve the dispute between the
involved parties in a peaceful manner and without any kind of difficulty.5
In Pakistan, process relating to arbitration have also been followed by various business
houses. The Arbitration Act of the year 1940 is considered to be the only Act in Pakistan that
deals with every kind of arbitration processes, which takes place on relation to the nation.6
However, it must be mentioned that the aforementioned Act does not deal with the process
relating to the acknowledgment and the enforcement of international arbitral awards in Pakistan.
The ‘New York Convention’ of the year 1958 is implemented in Pakistan, with the help of the
Recognition and Enforcement Act of the year 2011. This particular Act contains provision in
connection to process relating to the acknowledgement and the implementation of ‘international
arbitral awards’ in the nation of Pakistan. The focus of this study is the international arbitration
and the challenges that are faced relating to such international arbitration in the aforementioned
country.7
7. Format of the Study
The format that the report will be following has been mentioned below:-
5 Lanoszka, Anna. "Multinationals, international arbitration, and the world trade system: confronting the
inconvenient issues in the WTO." International Journal of Business and Economic Development (IJBED) 5.1
(2017).
6 Arbitration Act, 1940.
7 Anwar, Shaista. "International and Domestic Arbitration in Pakistan: Law and Practice: A Book Review." (2018):
146.

6TITLE
1. Introduction: The introduction in the form of a chapter will particularly emphasize on
the aim of the research and the backgrounds regarding the report. It will stress upon the
motive and purpose for conducting the research.
2. Literature review: The literature review will demonstrate the several principles and
simulations relating to international arbitration. On the basis of this, the report shall
recognize the challenges of arbitration faced in Pakistan and the possible solutions to
such challenges.
3. Research methodology: The research methodology in the form of a chapter inclines to
emphasize on the research procedures that have been made applicable in relation to the
study for proving the hypothesis attaining the objectives of the research.
4. Findings and Analysis: This chapter shall forward a discussion regarding the findings in
relation to collection of data and advance the discussion in connection to challenges of
arbitration procedures in Pakistan and the probable recommendations.
5. Conclusion and recommendations: The conclusive chapter shall forward a study and
examination regarding the findings and deliver recommendations in relation to the same.

7TITLE
CHAPTER 2 – LITERATURE REVIEW
OVERVIEW
This project shall be considered to be an expository literature, which forwards a
discussion in relation to the foundation and advancement of international arbitration in the
country of Pakistan. The varied discussion regarding the aforementioned topic includes
importance of arbitration globally, the progress of arbitration in the aforementioned nation and
the challenges or difficulties that are faced by Pakistan in connection to the implementation of
the process of arbitration in the country.
INTERNATIONAL ARBITRATION
According to Samuel P. Baumgartner, international commercial or financial arbitration
shall be considered to be an advocacy focused endeavor8. In this particular endeavor or process,
the parties that are involved, hire and engage specific lawyers or advocates having skills and
expertise regarding international commercial and financial matters. The parties that are involved
in this particular process, put their faith and belief in the lawyers or advocates hired by them. The
parties genuinely believe that the odds and likelihoods in relation to their success shall upsurge
consistently because of the experience, skills and expertise regarding their advocates. According
to Philip D. O’Neill, it may be said that clients are not the only individuals who contemplates
such kind of perception in relation to the lawyers and the advocates. Even the lawyers and the
arbitrators themselves have indicated that a good lawyer or advocate in the process of arbitration
proves to be material element in making a difference in connection to the result of the dispute.
8 Alavi, Hamed. "Arbitration and LC Fraud Disputes: a Comparative Approach." Russian Journal of Comparative
Law 2 (2016): 59-72.

8TITLE
According to Arif Hyder Ali and Henry G. Burnett, it may be stated that unlike a process
of litigation, a process relating to an international arbitration relies on detailed and
comprehensive written advocacy instead of oral representations and demonstrations at the
hearings9. According to Frédéric Gilles Sourgens, it may be said that lawyers or advocates in any
particular proceeding relating to international arbitration, repeatedly deliver to the arbitral panel,
numerous series of written arguments before the hearings begin10. The lawyers also submit
statements of the witnesses in written format, which covers the maximum portion of the
testimony, if not the complete direct testimony. However, it must be mentioned that a good
advocacy or argument in a written manner may not be only a matter relating to style, it may also
be considered to be essentially a matter relating to substance grounded on research and
investigation, and which is both intense and wide-ranging.
According to Lew, a primary significance in relation to international arbitration is the
element that international arbitration is reasonably free from any kind of control, partiality,
biasness or prejudice that may exist in the laws of the various nations11.
INTERNATIONAL ARBITRATION IN ASIAN COUNTRIES
For the past several years, it has been witnessed by the world community that there has
been an upsurge in the quantum of cross-border investments and transactions in the continent of
Asia. Such upsurge has resulted in an increase in the disputes in relation to the cross-border
businesses. The parties that are involved in such dispute related transactions, are more inclined
9 de Cossío, Francisco González. "International Arbitration: Past, Present and Future: Tribute to Bernardo Cremades
and Yves Derains (Arbitraje Internacional: Pasado, Presente y Futuro: Homenaje a Bernardo Cremades e Yves
Derains), by Carlos Alberto Soto Coaguila and Delia Revolledo Marsano de Mur (Editors)." (2016): 551-555.
10 Sourgens, Frédéric Gilles, Kabir Duggal, and Ian A. Laird. Evidence in International Investment Arbitration.
Oxford University Press, 2018.
11 Lew, Julian DM. "Increasing Influence of Asia in International Arbitration." Asian Dispute Review 16.1 (2014): 4-
9.

9TITLE
towards a process of international commercial arbitration in order to find a resolution to their
disputes. The process in respect of international financial arbitration demands a specific
infrastructure for the process. It may also be said that the process of arbitration is influenced by
the involvement of the judiciary in connection to the place where the process of arbitration is
being held. It must be mentioned that the nations of the Asian continent have responded and
retorted in connection to the aforementioned demands in an effective manner. The Asian
countries have by advanced their infrastructure in relation to the process of arbitration coupled.
The countries have made an effort in order to update and modernize their own laws relating to
arbitration12.
According to Simon Greenberg, the unparalleled development and progress of the nations
of the Asian Continent, led to an outpouring of investments and trade in the Asian region. A
particularly predictable and unavoidable consequence in relation to
such commercial undertakings or activities was the increase in the cross-border disputes, and
such disputes involved multinational organizations or corporations of various nations. The
international business community of the Asian Continent never exhibited any kind of
unwillingness or hesitancy in the acceptance and the implementation of international arbitration
as a practicable and feasible mechanism for resolution of disputes, unlike the nations of the
Western world at the beginning of the 20th century. Hence, it may be said that the process
relating to international financial arbitration has materialized as the mechanism, which is most
preferred for the resolution of disputes relating to investments and trade in the continent of Asia,
in this 21st century13. However, it may be mentioned that there is presence
12 Powell, Richard. "Perceptual, cultural and linguistic challenges facing Japan as a site of international
arbitration." International Arbitration Discourse and Practices in Asia. Routledge, 2017. 106-121.
13 Hayward, Benjamin. "Submission to the Public Consultation on Proposed Amendments to the 2013 HKIAC
Administered Arbitration Rules." Available at SSRN 3044218 (2017).

10TITLE
of little doubt that the establishment of well-advanced arbitral organizations or institutions will
provide the involved parties an improved possibility or opportunity for a structured and an
organized process of arbitration.
According to Yang and Chew, the chances and the prospects in relation to the progress
and advancement of the process relating to international arbitration in nations of Asia are
conditioned by the manner regarding the alterations and variations in the outlines of the
international or global economy. The functions relating to the process of arbitration are given
more importance, consideration, attention and thoughtfulness by the governments of the nations
of the continent of Asia14. However, it must be mentioned that the influence and impact of the
arbitrations is considered to be enthusiastically extended by the organizations in relation to
arbitration processes that exist in the specific areas or regions. The authors have also discussed
the aspects, which limit or constrain the advancements and progresses of international arbitration
in the continent of Asia15.
INTERNATIONAL ARBITRATION IN PAKISTAN
In Pakistan, the only legislation dealing with all kinds processes regarding arbitration, is
the Arbitration Act of the year 194016. The ‘New York Convention’ of the year 195817 is
implemented in the country of Pakistan, with the help of the ‘Recognition and Enforcement Act’
of the year 2011 and it pertains to the acknowledgement and implementation of the process
relating to ‘International Arbitral Awards’18.
14 Yang, L. S., and L. Chew. International commercial arbitration in Asia. JurisNet, New York, 2013.
15 Yang, L. S., and L. Chew. International commercial arbitration in Asia. JurisNet, New York, 2013.
16 Arbitration Act, 1940.
17 New York Convention, 1958.
18 Recognition and Enforcement Act, 2011.

11TITLE
According to Tilmann and Shinwari, in the nation of Pakistan the individuals generally
solve and seek resolutions in relation to their disputes and disagreements outside the premises of
the court. In the rural regions regarding the ‘Administered Tribal Areas’, Punjab, Sind and
Baluchistan such alternate methods for resolving disputes are considered to be customary
practices. The individuals of the aforementioned regions adhere to the traditions and customs that
have been forwarded by their ancestors, and these individuals do not adhere to the laws relating
to arbitration that exist in the present days of Pakistan19. However, it may be mentioned that
alternate methods regarding the resolution of disputes and disagreements in the urban regions of
the nation of Pakistan are not utilized as commonly as in the rural regions20. In the urban regions
of the nation, the arbitrators adhere to the laws of the present days. The arbitrators submit a
particular award in any particular court for the purposes of the implementation of the award. The
court having the jurisdiction regarding such matters forwards a ruling in relation to the decision
that has been delivered by any arbitrator, in case no involved parties raise any kind of objection
within the time period that has been stated in the Limitation Act of the year 190821.
Pakistan accepted and adopted the ‘Convention on the Recognition and Enforcement of
Foreign Arbitral Awards’ [Convention] of the year 195822, on the 14th day of the month of July in
the year of 2005. It adopted the Convention through the ‘Recognition and Enforcement
(Arbitration Agreements and Foreign Arbitral Awards) Ordinance’ in the year of 200523. The
Ordinance was ultimately implemented and enacted in the year of 2011. The primary purpose
and objective regarding the Act of 2011 was the acceptance and the adoption of the Convention
though the acknowledgement and implementation of the ‘foreign arbitral awards’ and ‘foreign
19 Mukhtar, Sohaib. "Settlement of Disputes by Way of Arbitration in Pakistan." World 3.4 (2016).
20 Ibid
21 Limitation Act, 1908.
22 Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 1958.
23 Recognition and Enforcement (Arbitration Agreements and Foreign Arbitral Awards) Ordinance, 2005.

12TITLE
arbitration agreements’24. The relevant sections of the 2011 Act, in relation to such
acknowledgement and implementation, are section 3, section 4, section 6 and section 725.
Therefore, the 2011 Act restricted the judicial discretion in connection to courts of Pakistan and
revoked the Arbitration (Protocol and Convention) Act of the year 193726. After the 2011 Act
was enacted, the creditors for international award filed applications in relation to the
acknowledgment and implementation of the foreign awards and grants on the ground that the
fresh and new legislation was more clear and unambiguous and also on the ground that the new
legislation had minimal possibility of judicial involvement or interference27. As per the 2011 Act,
the Courts shall not be able to refuse or decline any kind of application in connection to
acknowledgement and implementation of the foreign award. The courts shall be able to refuse
applications only when the applications would be in contradiction to the provisions that are
provided in Article V as stated in the Convention mentioned above28. However, in practicality,
the courts of Pakistan were unable to adapt and familiarize themselves in relation to the drastic
modification transformation of the law, and hence, there was delay in the acknowledgement and
implementation in connection to the foreign awards, which made the awards incompetent and
redundant, and unreliable or varying judgments were delivered in contradiction to the proposed
and recognized principles relating to arbitration. The case of Taisei Corporation versus A.M.
Construction Company (Private) Limited, PLD 2012 Lahore 45529 shall be considered to be a
relevant case in this regard. In this case, after the interpretation of section 14 as provided in the
Arbitration Act of the year 194030, the High Court of Lahore mentioned that the powers and
24 Recognition and Enforcement (Arbitration Agreements and Foreign Arbitral Awards) Act, 2011.
25 Ibid
26 Arbitration (Protocol and Convention) Act, 1937.
27 Menaker, Andrea. International Arbitration and the Rule of Law: Contribution and Conformity. Kluwer Law
International BV, 2017.
28 Recognition and Enforcement (Arbitration Agreements and Foreign Arbitral Awards) Act, 2011.
29 Taisei Corporation versus A.M. Construction Company (Private) Limited, PLD 2012 Lahore 455.
30 Arbitration Act, 1940.

13TITLE
authorities relating to the Court in connection to the acknowledgement and implementation of a
foreign award as per the 2011 Act31, are restricted. Hence, the common solution to seek and
pursue acknowledgement and implementation, as per section 14 as provided in the Act of 1940,
would continue to be available. However, afterwards such ruling was considered to be incorrect
because the application of the Act of 1940 can only be made in relation to domestic awards. The
Act of 1940 cannot be applied in connection to the foreign awards. Another significant case in
this regard is the case of Abdullah versus CNAN Group Spa, PLD 2014 Sindh 34932. In this case,
it was held that an award debtor shall not have the opportunity to invalidate a foreign award with
the help and assistance of a civil suit, which may be filed in contradiction to such award, as per
the provisions given in Article V relating to the Convention33. It was held by the Court that an
award debtor shall be able to refer to the points stated in Article V, only in defense in relation to
any particular proceeding, which may be commenced or instigated by the award creditor for the
purposes of the acknowledgement and the implementation regarding the foreign award34.
CHALLENGES FACED BY THE PAKISTAN
There are several issues in connection to the international arbitration in the nation of
Pakistan. The chief problem or issue in Pakistan is that most of the processes relating to
arbitration are not exercised or conducted, as per the provisions regarding the laws relating to
arbitration, they are generally conducted and exercised, as per the usages and customs of the
civilization and the society that are not provided in the Arbitration Act of the year 1940. In order
31 Recognition and Enforcement (Arbitration Agreements and Foreign Arbitral Awards) Act, 2011.
32 Abdullah versus CNAN Group Spa, PLD 2014 Sindh 349.
33 New York Convention, 1958.
34 Abdullah versus CNAN Group Spa, PLD 2014 Sindh 349.

14TITLE
to provide resolution for the disputes relating to the implementation, Panchayat and private Jirga
exist35.
Several cases may be discussed in connection to the situation mentioned above. The case
of Rossmere International Limited v Sea Lion International Shipping Inc., PLD 2017 Baluchistan
2936 can be considered to be an important case in this regard. This case is known for the unique
viewpoint of the judgment of the case. In the case, the High Court of Quetta acknowledged a
foreign award, however, disallowed the enforceability of the foreign award on the ground or
understanding that the award debtor did not possess or own any bank accounts or any assets
within the limits of the territorial jurisdiction in relation to the Court. It must be mentioned that
the procedural issue discussed in the aforementioned case, has directed the courts of Pakistan off
course in the preceding century. Such issues also crushed the objective and perseverance of
international arbitrations. Another case may be discussed in which the issue of delay had been
forwarded. The case of Louis Dreyfus SA Commodities v Acro Textile Limited, Civil Original
No.649 of 201237 shall be considered to be a relevant vase in this regard. In this case, the
respective judges did not pass any ruling regarding the matter, and hence, inordinate delay has
been suffered.
According to Mayer, the main purpose in relation to private international law shall be
considered to be the harmony and congruence regarding the solutions. Many tools exist in the
private international law in order to avert the conflicts38.
35 Wilske, Stephan. "International Arbitration and Its Dark Sides, in Particular Corruption: What Arbitral Institutions
Could and Should Do to Tackle Such Unwelcome Issues." Particular Corruption: What Arbitral Institutions Could
and Should Do to Tackle Such Unwelcome Issues (November 29, 2019). Contemporary Asia Arbitration
Journal 12.2 (2019): 147-176.
36 Rossmere International Limited v Sea Lion International Shipping Inc., PLD 2017 Baluchistan 29.
37 Louis Dreyfus SA Commodities v Acro Textile Limited, Civil Original No.649 of 2012.
38 Mayer, Pierre. "Conflicting decisions in international commercial arbitration." Journal of International Dispute
Settlement 4.2 (2013): 407-419.

15TITLE
SUMMARY
This chapter has forwarded discussion in relation to the international arbitration in the
country of Pakistan. It has provided an overview regarding the topic. The chapter of literature
review has provided the ideas and thoughts of several authors in relation to the principles of
international arbitration, international arbitration in the nation of Pakistan and the challenges that
the nation has been facing regarding the implementation of arbitral awards and foreign awards.

16TITLE
CHAPTER 3 - [Heading – indicative of chapter content] [700]
CHAPTER 4 - [Heading – indicative of chapter content] [2500]
CHAPTER 5 –CONCLUSION [1000]
APPENDICES [if applicable]

17TITLE
BIBLIOGRAPHY
Abdullah versus CNAN Group Spa, PLD 2014 Sindh 349.
Alavi, Hamed. "Arbitration and LC Fraud Disputes: a Comparative Approach." Russian Journal
of Comparative Law 2 (2016): 59-72.
Anwar, Shaista. "International and Domestic Arbitration in Pakistan: Law and Practice: A Book
Review." (2018): 146.
Arbitration (Protocol and Convention) Act, 1937.
Arbitration Act, 1940.
Cole, Tony, and Pietro Ortolani. Understanding International Arbitration. Routledge, 2019.
de Cossío, Francisco González. "International Arbitration: Past, Present and Future: Tribute to
Bernardo Cremades and Yves Derains (Arbitraje Internacional: Pasado, Presente y Futuro:
Homenaje a Bernardo Cremades e Yves Derains), by Carlos Alberto Soto Coaguila and Delia
Revolledo Marsano de Mur (Editors)." (2016): 551-555.
Hayward, Benjamin. "Submission to the Public Consultation on Proposed Amendments to the
2013 HKIAC Administered Arbitration Rules." Available at SSRN 3044218 (2017).
Lanoszka, Anna. "Multinationals, international arbitration, and the world trade system:
confronting the inconvenient issues in the WTO." International Journal of Business and
Economic Development (IJBED) 5.1 (2017).
Lew, Julian DM. "Increasing Influence of Asia in International Arbitration." Asian Dispute
Review 16.1 (2014): 4-9.

18TITLE
Limitation Act, 1908.
Louis Dreyfus SA Commodities v Acro Textile Limited, Civil Original No.649 of 2012.
Mayer, Pierre. "Conflicting decisions in international commercial arbitration." Journal of
International Dispute Settlement 4.2 (2013): 407-419.
Menaker, Andrea. International Arbitration and the Rule of Law: Contribution and Conformity.
Kluwer Law International BV, 2017.
Mukhtar, Sohaib. "Settlement of Disputes by Way of Arbitration in Pakistan." World 3.4 (2016).
New York Arbitration Convention, 1959.
Recognition and Enforcement (Arbitration Agreements and Foreign Arbitral Awards) Ordnance,
2005.
Recognition and Enforcement (Arbitration Agreements and Foreign Arbitral Awards) Act, 2011.
Rossmere International Limited v Sea Lion International Shipping Inc., PLD 2017 Baluchistan
29.
Sourgens, Frédéric Gilles, Kabir Duggal, and Ian A. Laird. Evidence in International Investment
Arbitration. Oxford University Press, 2018.
Taisei Corporation versus A.M. Construction Company (Private) Limited, PLD 2012 Lahore
455.
Wessel, J., and B. Pilbrow. "The Roles of Psychology in International Arbitration-A
Review." Transnational Dispute Management (TDM) 15.1 (2018).

19TITLE
Wilske, Stephan. "International Arbitration and Its Dark Sides, in Particular Corruption: What
Arbitral Institutions Could and Should Do to Tackle Such Unwelcome Issues." Particular
Corruption: What Arbitral Institutions Could and Should Do to Tackle Such Unwelcome Issues
(November 29, 2019). Contemporary Asia Arbitration Journal 12.2 (2019): 147-176.
Yamashita, Kenshiro, Tatsuya Emoto, and Kazuki Watanabe. "Sovereignty Immunity on
International Arbitral Awards in Asia: Based on New York Convention and Domestic Law in
Asia on Sovereign Immunity." ALSA (2017): 150.
Yang, L. S., and L. Chew. International commercial arbitration in Asia. JurisNet, New York,
2013.