Plures leges, sed leges faciunt arbitrum

Abstract

The paper analyses the continuing importance
of the seat –as well as the lex loci arbitri
– during all phases of an arbitration's life cycle. At
the same time, the paper shows that the law of
the seat of the arbitration is not the only one to
impose itself on any given arbitration. Rather, various
national arbitration laws may – and usually
will – come into play.