Арбитражно споразумение и пророгационно споразумение
Arbitration Agreement and Choice of Court Agreement

Comparative Analysis

Author(s): Kristian Raychev
Subject(s): Law, Constitution, Jurisprudence, International Law
Published by: Пловдивски университет »Паисий Хилендарски«
Keywords: choice of court; arbitration; recognition and enforcement of judicial acts; party autonomy; Hague convention; New York convention; international contracts; jurisdiction
Summary/Abstract: The report examines the two dispute resolution institutions in view of the fact that both arbitration agreement and choice of court are the result of the will of the parties to the legal relationship. The purpose of the report is to highlight the main differences between the two institutions in view of the existing positive law. Emphasis is placed on the requirements laid down in the relevant conventions for the validity of the arbitration and prorogation agreement, as well as the recognition and enforcement of final judicial acts.

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