In various legal systems, different approaches exist regarding provisional measures of protection in arbitration. In this regard, two approaches deserve special attention. While in the “free choice model” that is provided under the UNCITRAL Model Law of 1985, provisional measures of protection may be requested from the courts or from arbitral tribunals, while in the “court subsidiarity model,” which is provided under English law, some conditions have to be met in order to request provisional measures of protection from the courts. In the latter model, the courts are deemed as final resorts, not only in deciding on the provisional measures of protection but also for the enforcement of such decisions. In this regard, this article aims to explain some issues of the English Arbitration Act of 1996, such as the competent authorities for the provisional measures of protection, the conditions of their competence, enforcement of arbitral provisional measures of protection as well as the support of English courts in arbitral proceedings, where the seat of arbitration is outside England
ın varius legal systems have different troubles associated with provisional measures of protection in arbitration nin this regard is two hands deserved special attention while in the “free choice model” that is under the uncıtral model law of 1985 provisional measures of protection may be requested from the court or from arbitral tribunals while in the “court subsidiarity model” which is under english law some conditions have to be met in order to request provisional measures of protection from the crimea nin the latter model of enforcement procedures are provided by arbitration procedures such as the arbitration protection of such as in this regard to the arbitration policy of the implementation of the arbitration policy of the arbitration protection of such as in the implementation of the arbitration policy of such as in the arbitration policy of the arbitration policy of the arbitration policy of the arbitration policy of the arbitration protection of such a position of the arbitration policy of the arbitration protection of the implementation of the arbitration protection of the arbitration policy of the arbitration policy of the arbitration policy of the arbitration protection of the arbitration policy of the arbitration policy of the implementation of the arbitration policy of the arbitration policy of the arbitration protection of the arbitration policy of the arbitration policy of the implementation of the arbitration protection of the arbitration policy of the arbitration policy of
Alan : Hukuk
Dergi Türü : Ulusal
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