Abstract
The article presents a study which examines the conflicts of procedure between courts and arbitral tribunals in Africa to propose an argument for harmonization. It discusses the arbitration regimes in sub-Saharan Africa by exploring the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, the Organisation pour L'Harmonisation en Afrique du Droit des Affaires (OHADA) Treaty and the United Nations Commission on International Trade Law (UNICITRAL) Model Law on International Commercial Arbitration. It looks into the case studies about the legal issues of arbitration in Nigeria, South Africa and Sudan including the procedural jurisdiction of the Lufuno Mphaphuli case. Moreover, the meaning and implications of some basic concepts are explained.
Original language | English |
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Pages (from-to) | 65-102 |
Number of pages | 38 |
Journal | Tulane European and Civil Law Forum |
Volume | 25 |
Issue number | 5 |
Publication status | Published - May 2010 |