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اختيار القانون الذي يحكم موضوع النزاع
2 Choice of the law governing the substance of the dispute
What drives decisions about
the law governing the
substance of the dispute?
Two respondents added an additional factor
which they both ranked as ‘very important’, a
factor that was also raised by a number of
interviewees: the impact of choice of law on
the enforceability of the award. Some
interviewees explained that they will consider
where the award is likely to be enforced and
either select that law or another governing law
that would be consistent with that jurisdiction
(i.e. common law or civil law, or a law from
which the law of that jurisdiction originated) or
that is highly regarded by the courts of that
jurisdiction.
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