Introduction

Due to an increased number of investment treaties, investor-State disputes have been referred to arbitration based on the arbitration clauses in those treaties (hereinafter referred to as the "Investment Treaty Arbitration") and the number of such arbitration has been recently rapidly increased.[1] Besides, investment disputes have conventionally been referred to arbitration based on the arbitration clauses in investment contracts between States and individual investors (hereinafter referred to as the "Investment Contract Arbitration").[2] In the Investment ...