Introduction

There is a fragmentation in the African States' policymaking related to international arbitration. These diverging attitudes by African States towards international arbitration at the domestic level are also reflected at the supra-national level where contradicting policies can also be observed. While the Organization for the Harmonization of Business Law in Africa (hereinafter "OHADA") adopted the Uniform Acts on Arbitration and Mediation in 2017, aiming to promote arbitration, the South African Development Community (hereinafter "SADC") adopted its bilateral investment ...