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Choice of Law in International Arbitration (with Respect to Corresponding Legal Regulations in the Czech Republic)

This paper deals with the question of the determination of the applicable law in international commercial arbitration. In particular, it focuses on the determination of the substantive law governing the legal relationship of the parties, as the law which needs to be distinguished from the law applicable to the arbitration agreement and lex arbitri. It is argued that lex arbitri exercises great influence over the determination of the substantive law applicable to the merits and as such cannot be disregarded. However, the interaction works both ways, meaning that the substantive law pursuant to which the arbitrators rendered their decision may impact the recognition and enforcement of the award. Furthermore, the rules applicable in the Czech Republic are introduced, and as both the private international law and in connection herewith the lex arbitri recently underwent changes, a comparison is made between the former and current legislation. It can be concluded that despite the changes in wording, the fundamental principles remained untouched. The last part of the paper deals with the current international trends and the growing role of party autonomy. Theories according to which the arbitrators are not bound to follow any normative set of rules, are also discussed with the result that the transnational approach to arbitration cannot result in a complete detachment from any legal framework. Finally, the most common methods used by the arbitrators in order to determine the applicable substantive law are described.