An arbitration is governed by three areas of law:
(1) the law governing the substance of the dispute between the parties;
(2) the law of the arbitration agreement which governs the parties' right to submit disputes to arbitration and their obligation to meet any arbitral award (often referred to as the 'proper law of the arbitration agreement')1; and
(3) the procedural law of the arbitration (often referred to as the 'curial law of the arbitration')2.
In many cases the law of a single jurisdiction will govern all aspects of the arbitration, although it is common in international arbitrations for the
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