ABSTRACT
The selection of the legal seat of arbitration is fundamentally important as the legal seat of arbitration is one of the most significant and close connecting factors for the determination of law applicable to the validity of arbitration agreements, and subsequently the recognition and enforcement of arbitral awards by national or international law. Delocalised arbitration is detached from the procedural rules and the substantive law of the place of arbitration; the procedural rules of any specific national law; and the national substantive law of any specific jurisdiction. The purpose of challenging an arbitral award is to have it corrected in some way or more often have it annulled or set aside in whole or in part. There are two main ways of challenging arbitral awards: one is internal challenge via arbitral institutions/tribunals; and the other is recourse to the courts.
