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A comparative study of the rules governing the formation of arbitration agreements under Danish, English and Norwegian law. The relevant domestic legislation and international treaties, such as the New York Convention 1958, are considered in detail.
The book deals with the general rules of arbitration and contract law as well as distinct transport law rules. The central element of the book is the criteria which must be satisfies before a party is obliged to arbitrate a given dispute. However, certain elements of arbitral procedure, such as the principle of Kompetenz-Kompetenz are also discussed.
Of particular interest to the transport lawyer is the book's examination of the arbitrability of transport disputes under the international transport law conventions.