I. INTRODUCTION

There has been an explosive growth in the number of international arbitrations over the past twenty or thirty years. In the mid-1980s, a little over 50 states had acceded to the New York Convention. That number has now almost tripled to 140. In the mid-1980s, the UNCITRAL Model Law1 was just coming off the production line. It has now been adopted by over 50 states and used as a bench-mark for new laws on arbitration in many other states. No statistics are available for the intensely private ad hoc arbitrations, but experience suggests that they are increasing; and the picture is the same with institutional arbitrations. In the mid-1980s, the International Chamber of Commerce in Paris (“the ICC”) registered approximately 250 new cases each year. That figure has now more than doubled; and other arbitral institutions report similar, or even greater, increases in numbers, including the International Centre for Dispute Resolution2 and, of course, the International Centre for the Settlement of Investment Disputes (“ICSID”),3 which has been woken like a sleeping beauty by the princely kiss of investor/state disputes.