نوع مقاله : مقاله علمی - پژوهشی
عنوان مقاله English
نویسنده English
For a long time, England has been facing with serious obstacles such as judicial interferences in arbitral proceedings. After several modifications and amendments in the Arbitration Acts of 1950 and 1979, finally in the Arbitration Act of 1996, previous bars disappeared and more facilities for international arbitration have been created. Although English legislation system insists that enactment of Arbitration Act of 1996 is not influenced by UNCITRAL Model Law, similarities between these two judge otherwise.
International Trade Arbitration Act of Iran has followed UNCITRAL Model Law in several aspects. It has, however, attempted to comply more with internal circumstances of state. Enactment of Iran’s arbitration Act was just one year after the reform of English arbitration system in 1996, so there would be reasonable doubt to conclude that both England and Iran’s arbitration systems are influenced by UNCITRAL Model Law. Broadly speaking, this article seeks to clarify similarities between England and Iran’s arbitration systems to conclude that both Acts are derived impliedly from UNCITRAL policies.
کلیدواژهها English