Kluwer: Post-Brentwood Judicial Practice on China-Seated Arbitrations Administered by Foreign Arbitral Institutions

By Tereza Gao (Arnold & Porter), Ziyi Yao (JunHe LLP) and Lingyun Chen

It is well-recognized in the world of international arbitration that the curial courts—those at the seat of the arbitration—have supervisory jurisdiction over their local arbitral proceedings (the so-called “seat standard”). Despite this, Chinese courts have historically been reluctant to take on the mantle of this supervisory jurisdiction for arbitrations administered by foreign arbitration institutions within...