COMPARATIVE ANALYSIS OF ENFORCEMENT OF THE EMERGENCY ARBITRATOR'S DECISION

Аннотация:

Emergency Arbitrator refers to an arbitrator appointed by an arbitration institution directly by the parties to an arbitration agreement in the process of international civil and commercial dispute resolution ， due to the urgency of the situation before
the establishment of the formal arbitral tribunal. The decision of the emergency arbitrator in an emergency arbitrator
proceedure is an interim measure, and the enforcement of the interim measure is the key to the emergency arbitrator proceedure. There is no unified view on the nature of the decision of an emergency arbitrator. Hong Kong ,Singapore and New Zealand have directly provided for the enforceability of emergency arbitrations in their arbitration laws. There is still a lack of agreement in other countries or regions of the world on the enforceability of an emergency arbitrator's decision. The enforcement of decisions made by emergency arbitrators is still a controversial issue.