International Commercial Arbitration Award and the Grounds to Set It Aside: Comparative Legal Analysis of Regulation in Russia and Singapore

The purpose of the article is to conduct a comparative analysis processes for issuing, amending and supplementing awards by institutional international commercial arbitrations in Russian Federation Singapore, as well reviewing legal regulation setting aside arbitral current trends judicial practice this area these states. mechanism returning an award state courts consideration within framework arbitration analyzed article. This paper examines provisions national legislation Singapore governing issues arbitration, regulations organizations represented International Commercial Arbitration Court at Chamber Commerce Industry Center; analyzes unified norms law, centers Singapore. process issuing has number features that may indirectly affect outcome dispute. also contains additional (compared generally accepted) grounds — fraudulent or corrupt motives; violation fundamental principle natural justice, while specific approaches essence were developed practice. Of particular interest pro-arbitration active position court regarding possibility dispute from criteria such return.