In dispute resolution the two most common forms of dispute resolution, which require and a greement, are arbitration and adjudication. Internationally, most large-scale infrastructure projects provide for adjudication of their disputes with referral to arbitration thereafter according to international standards developed by such groups as the International Chamber of Commerce (ICC) or the Chartered Institute of Arbitrators. Increasingly, arbitrators have to come to grips with electronic disclosure, that is e-disclosure of electronically stored information (ESI). The fact of the matter is that currently the issue of electronic disclosure does not come up that often in international arbitrations. The troubling aspect of this decision is that both the English High Court and Court of Appeal took it upon themselves to set aside, in effect, an award of an international arbitration tribunal where the arbitrators correctly applied French law. It shows where the UK courts had so agreed, that the arbitrators had properly applied the correct legal test under French law.