This Article will analyze this trend [the liberal tradition in international commercial arbitration] and attempt to assess its impact on the efficiency of international commercial arbitration as a viable alternative to litigation before the national judiciary. Where appropriate, the new laws will be compared to the UNCITRAL Model Law (the "Model Law"), today's archetype of modern commercial arbitration laws. Finally, this Article will focus on the possible influence of the new laws on arbitration laws of other states, taking the Federal Republic of Germany as an illustrative example.
Klaus Peter Berger,
The Modern Trend Towards Exclusion of Recourse Against Transnational Arbitral Awards: A European Perspective,
12 Fordham Int'l L.J. 605
Available at: http://ir.lawnet.fordham.edu/ilj/vol12/iss4/1