Challenging the constitution of an arbitral tribunal in an application for annulment

The application for annulment of an arbitral award must not constitute a second way to challenge the constitution of the Arbitral Tribunal by a party who has belatedly challenged an arbitrator (Cour de cassation, 1st Civil chamber, 15 June 2017, no. 16-17108).   A telecommunications company and an African state were joint shareholders of a …

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