Introduction
I - The Area of Inquiry: International Commercial Arbitration
II - The Object of Inquiry
III - The Method and Purpose of the Inquiry
1. Theories on the Lex Arbitri
I - Introduction to the Notions
II - Seat Theories
III - Legal Localization
IV - Approaches to Delocalization
V - Concluding Remarks: Desiderata
2. Representative Municipal Laws and Suggested Model of Arbitration Regulation
I - Localization by Choice of Law: Its Shortcomings and Abandonment
II - The Basic Tenets of Modern Arbitration Law
III - The Seat as the Focal Point in International Arbitration: Its Jurisdictional Title and Functions
IV - Conclusions
3. Human Rights Law Requirements - Jurisdictional and Substantive
I - The Principal Obligations
II - Arbitration Agreements as Waivers of the Right to a Court: Formal Requirements
III - Material Requirements under Article 6(1)
IV - Are Arbitral Tribunals bound to Apply the ECHR?
V - An International Obligation to Control Arbitral Proceedings?
VI - Conclusions
4. Arbitral Practice: Conflicts and Material Rules on Procedure
I - A Survey of Arbitration Rules
II - Overview of Arbitration Practice with Particular Reference to ICC Practice
III - General Principles of Arbitral Procedure
5. Arbitrations involving a State or Analogous Entity: Their Procedural Régime and its Relevance
I - Defining the Issues
II - The Iran-United States Tribunal
III - Foreign Investment Treaty Arbitration
IV - Ad hoc Proceedings involving States or International Organizations
V - Conclusions
6. Enforceability of Awards annulled in their State of Origin
I - The General Convention Framework
II - The Case-law
III - The Proper Limits for Discounting Annulment
IV - The Case for Restraint
V - Conclusion
7. The Requisite Degree of Connection between the Award and Municipal Law
I - Some Clarifications
II - Foreign and Non-Domestic Awards
III - Awards of the Iran-United States Claims Tribunal
IV - Anational and Stateless Awards
V - Conclusions
Conclusions
Bibliography