Comparison of Procedures Related to the Adjudication, Recognition and Enforcement of Decisions of International Commercial Arbitration in Russia and Japan

Abstract

The article attempts to compare the decision-making process of institutional international commercial arbitration in Russia and Japan. In the consistent and comprehensive manner, the author compares the norms of the State law, the internal provisions of institutional arbitration organizations represented in the form of the International Commercial Arbitration Court at the CCI and the Japanese Commercial Arbitration Association, as well as unified norms of international law and bilateral agreements. The issues of the arbitrator's special opinion, distribution of arbitration costs of the parties involved in the case, out-of-court settlement, identification and correction of errors, interpretation of decisions are considered. Attention is given to such an important issue as recognition and enforcement of a foreign arbitral award. At the end of the article, conclusions are drawn about the advantages and disadvantages of the arbitration organizations under consideration.