Introduction

This article analyses whether disregard by the arbitral tribunal of the choice of law made by the parties may be considered an excess of power or a procedural irregularity, thus leading to the invalidity or unenforceability of an award. Arbitration is, as known, an out-of-court method of dispute resolution that is mostly based on the will of the parties. The arbitral tribunal is bound to follow the parties' instructions because it does not have any powers outside the scope of the parties' agreement. Tribunals are therefore, and correctly, very reluctant to deviate from ...