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Do Mandatory Rules of Public Law Limit Choice of Law in International Commercial Arbitration
1992
The general principle of party autonomy allows contracting parties to choose the substantive law that will govern their contract. In the international arbitration arena, arbitrators are faced with the unanswered question of whether to apply or consider relevant mandatory rules ofpublic law which were not chosen by the contracting parties. Neither international arbitration conventions nor national arbitration laws have answered this important question. An arbitrator who decides to apply the
doi:10.15779/z38rp9x
fatcat:hmtymtkw7fhxrhdxekvcu6kzd4