This panel will explore the evolving and sometimes divergent role of national courts in supporting or intervening in the arbitral process, with a focus on London, Paris and Singapore as key jurisdictions.
As arbitration continues to grow in complexity and global reach, courts are increasingly called upon to exercise their supervisory powers (whether through anti-suit injunctions, worldwide freezing orders, or the set aside and enforcement of final and/or partial awards). Yet, the approaches taken by courts in different jurisdictions are far from aligned.
Anti-suit and freezing injunctions: contrasting the English courts' stance with the French courts', and how this plays out in cross-border disputes, including recent cases involving Singapore.
Setting aside awards for lack of jurisdiction, and remission to tribunals: a comparative analysis of recent decisions from London, Paris, and Singapore, including how courts balance finality with fairness.
The impact of fraud allegations and how they influence judicial willingness to intervene in arbitral outcomes.
Interim measures in construction arbitrations, such as injunctions for performance bonds and enforcement of partial awards (highlighting divergent interpretations under the New York Convention).
Reform of the UK Arbitration Act and its implications for court powers and arbitral autonomy.