For international arbitrations, the system of law governing the arbitration itself (the /ex arbitri) has more practical importance than the parties often think. It may be even more important than the system of law governing the substance of the litigation. According to the author, the parties should determine the lex arbitri in their arbitration clause by choosing the place of arbitration. They should not leave such a choice to arbitral institutions or arbitrators.
The author notes that this work "is only a general and rather practical introduction to very difficult legal problems (especially in private international law), that require a much more sophisticated approach. ' The article is based on a paper delivered at a conference cosponsored by the American Arbitration Association and the International Chamber of Commerce held in New York City on September 28 and 29, 1978. It also appears in French in the periodical Droit et pratique du Commerce International, edited by Masson in Paris.