A Comparative Overview of Arbitration Laws: Swedish Arbitration Act 1999, English Arbitration Act 1996 and Russian Federal Law on International Commercial Arbitration 1993
Bibliographic record
Abstract
AS A sweeping generalization, it would be fair to say that differences in national legislation on arbitration under the various legal regimes of Sweden, England and the Russian Federation in the case of the average arbitration will not have any tangible impact on the course of the proceedings.1 There are three main reasons: ... However, there are a number of specific differences between the arbitration laws in England, Russia and Sweden and practitioners would be well advised to take these into account when drafting arbitration clauses and also when proceeding to arbitration in any particular jurisdiction. The arbitration laws of England, Russia and Sweden presently in force are all the result of recent legislation (1996, 1993 and 1999 respectively). All of them therefore without a doubt represent state-of-the-art proponents of arbitration law. Most arbitration laws which have been enacted in recent times have incorporated the UNCITRAL Model Law more or less wholesale (examples are Germany, Australia, Canada and Mexico). This has ensured a standardized approach to procedural issues arising in arbitration. However, neither England nor Sweden has chosen this approach; instead the legislatures in these countries have decided to build on previous domestic history of the law and practice of arbitration. But in so doing these countries as far as possible have taken the solutions offered by the Model Law into consideration.2
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.003 | 0.007 |
| Meta-epidemiology (narrow) | 0.001 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.009 | 0.016 |
| Science and technology studies | 0.002 | 0.002 |
| Scholarly communication | 0.006 | 0.003 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.002 | 0.002 |
| Insufficient payload (model declined to judge) | 0.005 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".