Kluwer: The Res Judicata Effect of Prior Awards in an International Arbitration Seated in Korea

An international arbitral tribunal seated in Korea addressing the res judicata effect of a prior arbitral award is faced with the question of whether the res judicata effect should be determined in accordance with the procedural law of Korea or in accordance with the autonomous, transnational rules that are suited to international arbitration. While divergent views are possible, Korean commentators seem to favour the latter approach.