ABSTRACT
International commercial arbitration is in many respects a unique legal phenomenon. Characterized among the historically most ancient forms of dispute resolution and preceding litigation, it remained scarcely used for centuries. Its revival in the twentieth century and its later, rapid expansion have been an object of increased attention from legal doctrine and its different theorizations. Arbitration has been characterized as a particularly efficient way of exercising party autonomy, increasingly endorsed by States along with loosening the girdle of judicial control. It has thus been approached as a fulfilment of the doctrine of States’ possible non-intervention into the commercial sphere in the context of the overall transnationalization trends of commercial law.1
