Originally from American Review of International Arbitration - ARIA

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I. INTRODUCTION
In the arbitration proceedings of CME v. The Czech Republic1 (commonly
known as the “Lauder” case) the Stockholm-based tribunal rendered a decision
signed by only two of the three arbitrators. One of the two party-appointed
arbitrators refused to sign the arbitral tribunal’s decision which found that the
Czech Republic had breached an agreement with the Netherlands on mutual
protection of investment, and ordered the Czech government to settle the damages
that CME incurred. At the end of a 179-page partial decision the tribunal
attached an explanation regarding the failure of one arbitrator to sign the award.