Summary

An investment contract often includes an arbitration clause providing for commercial arbitration. The availability of competing dispute settlement procedures means that two arbitral tribunals will have jurisdiction over the dispute arising from the common factual background. Such jurisdictional overlaps may result in multiple arbitral awards resolving substantially the same dispute or substantially the same issues. This article explores the possibility of recognizing effects of an award rendered in a related contractual dispute in the parallel or subsequent investment arbitration. It ...