Replacing several centuries of piecemeal legislation and random judicial decisions, the English Arbitration Act 19961 (hereinafter the Act) provides the first truly systematic and comprehensive legal framework for arbitration of commercial disputes in England.2 The legislation caps almost two decades of flirting with (and skirmishing around) arbitration law reform,3 beginning with the abolition, in 1979, of the procedure by which awards had been subject to systematic review on their legal merits.4 Some had felt that these statutory changes did not go far enough,...
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