Arbitration has become an essential tool in global trade because it provides companies with a trustworthy and impartial way to settle disputes. The need for fair, efficient, and enforced processes has grown in tandem with the expansion of international trade. With arbitration, the parties can choose their own arbitrators, procedures, and location for the arbitration, all while maintaining privacy and having some leeway. Arbitration is well-suited to cross-border conflicts due to its widespread acceptability, as evidenced by treaties such as the New York Convention (1958).

International and domestic arbitration in India are both codified in the 1996 Arbitration and Conciliation Act. The goal of the Act, which is based on the UNCITRAL Model Law, is to make it easier to implement foreign awards, decrease court intrusion, and increase party autonomy. Aiming to standardize Indian practices with those of other countries, subsequent revisions in 2015, 2019, and 2021 aimed to simplify processes, promote institutional arbitration, and do just that. Indian judicial statements, such as the seminal rulings in Amazon.com NV v. Future Retail (2021) and Bharat Aluminium Co. v. Kaiser Aluminium (2012), show a progressive trend towards arbitration-friendly case law.

There are still major obstacles to overcome, even with recent advances. The effectiveness of arbitration in India is hindered by court interference, inconsistent procedures, and lengthy delays. International frameworks like the UNCITRAL, the ICC, and ICSID, on the other hand, place an emphasis on impartiality, institutional efficacy, and limited judicial intervention. The purpose of this comparative study is to assess India's standing in relation to global norms and to recommend changes that would improve the country's arbitration system.

This research adopts a doctrinal and comparative legal methodology to analyze arbitration under Indian law and its alignment with international frameworks. The study relies primarily on the following sources:

1.      Primary sources:

• Statutory texts, including the Arbitration and Conciliation Act, 1996 (with 2015, 2019, and 2021 amendments).
• International instruments such as the UNCITRAL Model Law, ICC Rules, ICSID Convention, and the New York Convention.
• Landmark judicial decisions shaping arbitration in India and internationally.

2.      Secondary sources:

• Scholarly articles, books, reports, and commentaries on arbitration law and practice.
• Publications from international arbitration bodies and institutional reports.

The research employs qualitative analysis to interpret legislative provisions, judicial reasoning, and institutional practices. A comparative framework is applied to examine similarities and divergences between Indian arbitration and global standards in three dimensions:

• Procedural aspects (party autonomy, timelines, judicial intervention).
• Institutional aspects (role of arbitral institutions, case management, arbitrator neutrality).
• Enforcement aspects (recognition of awards, compliance  with international conventions).

Data and findings are categorized thematically to identify best practices, highlight gaps, and propose reforms to strengthen India’s arbitration system for international trade.

Most people are familiar with arbitration as a method of ADR. In arbitration, the disputing parties agree to have the matter heard by a neutral third party who, after reviewing the evidence and arguments, provides a binding decision (the "arbitral award"). Unlike litigation in domestic courts, which is grounded on a lack of consent, arbitration is legitimate since the disputing parties have agreed to it. Disputes in international trade can be neutrally and reliably resolved by arbitration because contracts often span more than one legal system (Born, 2021).

Arbitration in the International Trade Context

The worldwide scope of arbitration in international commerce makes it unique. It is possible to avoid the pitfalls of international litigation by opting for arbitration when dealing with parties from diverse cultural, linguistic, and legal backgrounds. Consider a scenario where an arbitral tribunal based in Singapore or London determines the procedures to be followed in order to settle a dispute between an Asian importer & European exporter. Due to its adaptability and the fact that it offers legal certainty, arbitration is a more appealing option for international trade (Redfern & Hunter, 2015).

Key Features of International Trade Arbitration

1.    Party Autonomy: Participants' independence is crucial to the concept of international arbitration. This procedure gives the disputing parties a say in almost every facet of the arbitration:

• The body of legislation that regulates contracts (lex-contractus).
• The bodies of law that regulate arbitration procedures (lex-arbitri).
• The location of the arbitration, which establishes the jurisdictional function of domestic courts.
• Methods of communication, especially those involving international commerce.
• The number and credentials of the arbitrators who will sit on the panel.

The autonomy of political parties has been supported by multiple judicial decisions. The United States Supreme Court upheld the idea that parties engaged in international trade had the freedom to select arbitration as their technique of dispute settlement in the instance of Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc. (473 U.S. 614, 1985).

2.   Neutrality: A further crucial aspect of international arbitration is its capacity to maintain objectivity. By consenting to have their dispute arbitrated before an impartial authority in a neutral place, the parties can avoid the potential for bias in a domestic court. British Supreme Court decision in Dallah Real Estate and Tourism Holding Co. v. Pakistani Ministry of Religious Affairs ([2010] UKSC), for example, the UK Supreme Court emphasized the significance of judicial restraint and the need to follow international arbitration procedures, including in cases involving delicate state interests.

3.  Adaptability: Arbitration processes are flexible enough to accommodate the specific needs of commercial contracts as well as the preferences of all parties. Arbitral rules permit procedural innovations such as rapid arbitration, virtual hearings, and limited discovery, in contrast to conventional court procedures.

4.   Finality: One goal of arbitration decisions is to make them legally enforceable. There are few reasons why they can be challenged, and those that are typically limited to issues of public policy, excessive jurisdiction, or procedural flaws. This approach minimizes the likelihood of drawn-out appeals and guarantees speedy resolution of issues. To ensure that arbitral rulings are final, courts may only refuse execution on carefully defined grounds, as stated in the UNCITRAL Model Law (Art. 34) & New York Convention (Art. V).

Importance of the Concept in International Trade

A delicate balance between the parties’ autonomy, objectivity, flexibility, and finality is fundamental to the concept of arbitration. All things considered, these are the main reasons why arbitration is becoming more popular in international trade, since it offers several advantages over litigation. Because arbitration makes contractual commitments enforceable regardless of location, it is a tool for settling disputes and a guarantee of legal certainty in an increasingly worldwide economic environment.

Three fundamental elements support international commercial arbitration: the New York Convention, which acknowledges and enforces such arbitration, the UNCITRAL Model Law, which provides a framework for national laws, and the statutes particular to each country’s seat, which offer procedural law and judicial backing. They promote enforceability, party autonomy, & limited judicial participation while paving the path for reforms and judgments that are peculiar to a certain jurisdiction.

New York Convention (1958)

The UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards, sometimes referred to as the "cornerstone" of international arbitration, lays out two crucial conditions. To begin, in cases where an arbitration agreement is valid, the court is required to send the parties to the arbitration. The second is that, with very limited exceptions for legitimate defenses, domestic courts are bound to recognize and support international judgments. The majority of enforcement authorities have a limited view of the following grounds: incapacity, invalid agreement, improper notification, abuse of power, violation of due process, non- arbitrability, & public policy. This is due to the fact that they have been swayed by opinion and case law that favors enforcement. As of 2025, 172 states will have become parties to the Convention, making its reach broader than that of most multilateral trade or investment deals.

Prior studies and guidelines have highlighted practical concerns.

1)  Courts do not re-evaluate the merits,

2)     According to UNCITRAL and specialized guidelines, if the parties’ agreement is substantively valid, formal flaws rarely merit refusal.

3)  This is because "public policy" is defined as international/public policy, not parochial.

4)  These similarities are seen in both Secretariat materials and practitioner studies that are used to assemble national decisions under Article V.

One major benefit of arbitration over court verdicts in international trade is the predictable enforcement method for decisions issued in one country and enforced in another. This is made feasible by the widespread membership and common defenses of the Convention.

UNCITRAL Model Law (1985, amended 2006)

An impartial and all-encompassing model law for the seat’s legislation is the UNCITRAL Model Law. Its fundamental characteristics, including kompetenz-kompetenz, separability, tribunal powers, interim measures, court assistance, and restricted set-aside reasons, have been standardized by other jurisdictions through adoption (with variances). Significant amendments were adopted by UNCITRAL in 2006, including: (a) a revised definition and form of the arbitration agreement (Article 7), (b) a new Chapter IV-A establishing a full regime for interim proceedings and preliminary orders, (c) clarification of recognition/enforcement of awards (Article 35), and (d) the addition of Art. 2A on international interpretive principles. Modern methods of contracting, such as electronic communications, and the necessity for efficient temporary relief prompted these changes. The Model Law aims to reduce seat-selection risk and procedural uncertainty for cross-border parties by upholding party autonomy, minimal court interference, and harmonization across adopting jurisdictions. The UNCITRAL Explanatory Notes and other scholarly works provide  credence to  this.

National Arbitration Laws

The framework is provided by the Convention & Model Law, but the lex arbitri and the scope of judicial monitoring are determined by national statutes.

India — Arbitration and Conciliation Act, 1996 (as amended 2015, 2019, 2021)

The Act of 1996 in India, which originated from the Model Law, has been substantially revised to bring it up to date and more effective. The 2015, 2019, and 2021 amendments brought about numerous notable changes, such as shorter timeframes for award issuance, less judicial intervention, higher standards of impartiality for arbitrators, institutional backing for arbitration (such as provisions relating to the Arbitration Council of India), and enhancements regarding stays of enforcement in cases where a set-aside is requested. These reforms were implemented with the goal of making India a more desirable seat of justice and reducing the use of delay tactics in court procedures.

2015 Amendment – Efficiency and Judicial Restraint

A historic reform, the 2015 Amendment Act sought to restrict judicial influence and decrease delays. Section 29A, which sets a rigorous 12-month deadline for arbitral tribunals to produce awards, can be extended by 6 months with party approval, and is one of the most significant sections. The goal was to reduce the length of the proceedings, which is often said to drag on in Indian arbitration.

The amendment further tightened the criteria for court involvement under Section 34, making it such that only specified grounds conforming to the New York Convention could be utilized to vacate judgments. More explicit definitions of "public policy" were also introduced to prevent its misuse. The filing of a challenge does not, on its own, require the enforcement of the award to be stayed, as was amended in Section 36 to further dissuade losing parties from employing delay tactics.

Together, these changes demonstrated India’s shift toward an enforcement-oriented framework and brought the Act into line with worldwide best practices (Singh, 2016).

2019 Amendment – Institutional Arbitration and Structural Reforms

By placing an emphasis on institutional arbitration, the 2019 Amendment Act bolstered the arbitration structure even further. To guarantee professionalism and quality in arbitration, the amendment suggested forming the Arbitration Council of India (ACI) as an autonomous authority to evaluate arbitral institutions and accredit arbitrators. The goal of this change was to make ad hoc arbitration less of a liability and more of a reliable alternative for India. The credentials and neutrality criteria for arbitrators under the Eighth Schedule were further clarified in the 2019 changes, although they were later modified in 2021). Also, even though the strict 12-month limit was deemed unimportant for international corporate arbitration, steps

were taken to promote the prompt resolution of such cases. India aimed to follow the lead of other prominent global arbitration centers, such as Singapore and London, by moving toward institutionalization. These cities have established arbitral institutions that give administrative assistance and credibility.

2021 Amendment – Neutrality and Enforcement Safeguards

To improve neutrality and fortify enforcement protections, the 2021 Amendment Act makes some specific amendments. First, it did away with the 2019 Act’s Eighth Schedule, which had severely limited the pool of potential arbitrators by demanding things like Indian legal qualifications as an absolute minimum. This change made India more appealing as a venue for arbitration since it allowed international arbitrators to participate.

Second, the amendment of 2021 made rules regarding stays of enforcement more stringent. The courts can terminate the arbitration procedure if they discover that the arbitration agreement or decision contains obvious errors (Section 36). While proponents see this as a measure to keep the arbitral process honest, detractors say it could lead to further court interference. The two main objectives of these revisions were to keep India’s arbitration competitive on a worldwide scale and to make sure that arbitral processes were fair.

Cumulative Impact of Reforms

India has substantially updated its arbitration system with the 2015, 2019, and 2021 modifications. The changes brought the enforcement mechanisms in line with international norms, fostered institutional arbitration, neutrality among arbitrators, and a decrease in delay tactics. Taken as a whole, these reforms attempted to position India as an alternative to more established Asian centers for arbitration, such as Singapore and Hong Kong. Still, there are obstacles to overcome, such as raising awareness among companies, establishing more reliable arbitral institutions, and guaranteeing consistent court interpretation. But these changes show that India is strong in its support for arbitration and its determination to help international investment and trade by establishing trustworthy dispute settlement processes.

United States — Federal Arbitration Act (FAA)

In 1925, Congress created the Federal Arbitration Act (FAA), which is the primary statute governing arbitration in the United States (9 U.S.C. §§ 1-16). According to Moses (2017), the main objective was to ensure that arbitration agreements would be treated fairly by courts and eventually be considered "on equal footing" with other contract forms. It makes no difference whether the parties are located inside or between states; the FAA applies to all commercial arbitration agreements involving commerce. Due to the broad interpretation of the Act by U.S. courts, the government has a strong policy in favor of arbitration and limits the power of courts to refuse enforcement.

The FAA is unique in that arbitral decisions are subject to limited judicial review. According to 9 U.S.C. §10, an arbitrator’s decision can be invalidated in three ways: (a) if the arbitrator shows obvious bias or corruption; (b) if the arbitrator does something wrong, like ignore important evidence; and (d) if the arbitrator abuses their power. Courts have repeatedly and extensively emphasized these issues, reflecting Congress’s intention to safeguard the finality of arbitration (Born, 2021).

Southland Corp. v. Keating (465 U.S. 1, 1984)

The United States Supreme Court deliberated on the matter of whether state courts were required to adhere to the FAA in the case of Southland Corp. v. Keating. The franchisees’ claims of violations of the California Franchise Investment Law, which required the use of judicial proceedings instead of arbitration to settle specific concerns, sparked this conflict. Due to the policy’s binding nature on both federal and state courts, the Court determined that state statutes conflicting with the FAA’s national goal of encouraging arbitration could not be enforced. The decision’s impact on the expansion of the FAA’s authority to prohibit states from passing laws that are adverse to arbitration was substantial. Southland is a landmark case that upholds the FAA’s preemptive power over state law, even though it has been challenged by certain experts for federal overreach.

England & Wales — Arbitration Act 1996 (as reformed in 2025)

The Arbitration Act of 1996 is both novel and consistent with the UNCITRAL Model Law, setting it apart from other arbitration-friendly acts in the UK. Procedural autonomy, limited judicial interference, and tribunal neutrality are among the significant concepts codified, as is Section 69, which allows appeals on matters of law (within the bounds of party opt-out). The Law Commission started reviewing the Act in 2021 to make sure it is still "fit for purpose," particularly because other jurisdictions have updated their arbitration systems. "Evolution, not revolution" is a fitting description of the 2025 reform, which instead focuses on targeted modifications to improve efficiency and clarity while preserving London’s position as a leading arbitration seat.

Key Reforms in the 2025 Act (Royal Assent February 2025; Entry into Force August 2025)

The "Arbitration Act 2025" received Royal Assent on February 24, 2025. On or around August 1, 2025, regulations are likely to be put in place to enforce the most important parts.

1.      Governing Law of Arbitration Agreements: According to the new default rule, the law of the seat will govern the arbitration agreement unless the parties specify otherwise. This supersedes the prior common law default, which was based on Enka v. Chubb (2020), and would have applied the underlying contract law.

2.      Tribunal Power to Summary-Dispose Issues: It is now within the jurisdiction of tribunals to promptly reject claims or defenses that have "no real prospect of success," which is a criterion that is comparable to summary judgment in civil courts. However, this ability will only be employed if all parties consent to it.

3.      Streamlined Jurisdictional Challenge Procedure (Section 67): While reviewing an arbitral tribunal’s jurisdictional decision, courts are now required to refrain from conducting entire re-hearings of evidence or new arguments. Instead, they can only admit new arguments if they were not reasonably available previously and are subject to the court’s interests-of-justice discretion.

4.      Emergency Arbitrator Recognition: The system for emergency arbitration has been approved. In such instances, the arbitrators have the power to make orders that can be enforced by courts (for example, using Section 44) and even by third parties.

5.      Codified Duty of Arbitrator Disclosure: As a continuation of the obligation of disclosure established in Halliburton v. Chubb (2020), Section 23A states that arbitrators must disclose everything that could cause a reasonable person to question their impartiality, including information that they are properly required to know.

6.      Enhanced Arbitrator Immunity: There are stronger safeguards in place to protect arbitrators: in contrast to the need that a resignation be "unreasonable" to trigger any costs responsibility, the liability for removal-related costs only arises upon bad faith.

7.      Clarified Court Support Powers (Section 44): A practical innovation for complex disputes is that courts can now issue supporting orders (such as evidence preservation or freezing) against third parties, rather than only listed arbitration parties.

8.      No Statutory Confidentiality: Although there are still confidentiality protections in place through institutional regulations (such as LCIA Rule 30), the Act does not mandate confidentiality by statute, favoring flexibility over a rigid approach. An astute update, the 2025 Arbitration Act maintains the fundamental benefits of the 1996 law while making it more adaptable to the needs of modern arbitration. It guarantees that England and Wales will continue to be a leading arbitration venue globally by enhancing procedural tools and providing improved clarity.

The development of arbitration law has been significantly influenced by Indian courts, which are frequently contentious. Interventionist interpretations have sometimes caused Indian arbitration law to depart from international standards, despite the fact that seminal decisions have generally brought it into line with them. The way arbitration is seen and used in India has been greatly impacted by the judiciary’s shifting position, especially when it comes to matters like the appointment of arbitrators, the power of arbitration panels, and the implementation of foreign decisions.

Appointment of Arbitrators

The independence of the parties, especially in choosing the arbitrators, is one of the fundamental principles of arbitration. However, these roles have traditionally been undertaken by Indian courts, which has occasionally made it difficult to distinguish between judicial & administrative duties.

A seven-judge Constitution Bench of the Supreme Court decided in SBP & Co. v. Patel Engineering Ltd. (2005) 8 SCC 618 that the Chief Justice’s function, as outlined in Section 11 of the Arbitration & Conciliation Act, 1996, was judicial in nature rather than administrative. By looking into preliminary matters including the arbitration agreement’s legitimacy, the dispute’s arbitrability, and whether there are any difficulties at all, the Chief Justices (or those they designate) may have greater discretion in the arbitration process, due to this interpretation.

Although this increased trust in the outcome of some cases, it was criticized for resulting in unnecessary delays and judicial overreach.

The Supreme Court later decided in TRF Ltd. v. Energo Engineering Projects Ltd. (2017) 8 SCC 377 that an ineligible party could not propose another party to serve as an arbitrator. It was justified by the idea that any adjudication system had to remain impartial and independent. The Court made it clear that the arbitration procedure must be impartial and free from actual or perceived bias, particularly when it comes to contracts where one party may have undue power.

This precedent was upheld and expanded in the Perkins Eastman Architects DPC v. HSCC (India) Ltd. (2019) 20 SCC 760 case. The Court upheld the trend toward institutional arbitration by ruling that even party-initiated appointments, especially those made by state institutions, could raise questions regarding impartiality.

Arbitral Self-Determination of Jurisdiction

The Kompetenz-Kompetenz hypothesis states that an arbitral tribunal may make decisions on matters that come within its jurisdiction, such as disagreements regarding the validity or arbitration agreement. Section 16 of the 1996 Arbitration and Conciliation Act acknowledges this concept.

The Supreme Court upheld the idea in the case of K.K. Modi v. K.N. Modi (1998) 3 SCC 573, ruling that arbitral tribunals have the primary authority to decide their own jurisdiction, even though courts may review them later. This was perceived as an effort to strengthen the arbitral panel’s independence and decrease court intervention in the early stages of the process. This idea was given more nuance by a subsequent Court decision in S.B.P. & Co. v. Patel Engineering Ltd., which stated that although arbitral tribunals have the power to determine their own competence under Section 16, courts, like arbitral tribunals, can make preliminary decisions when asked to do so under Section 11 in order to choose arbitrators. In the years that followed, pro-arbitration verdicts gradually reduced the interpretational strain that this dualism had produced.

The Supreme Court’s decision in Garware Wall Ropes Ltd. v. Coastal Marine Constructions & Engineering Ltd. (2019) 9 SCC 209, among other things, ruled that arbitration agreements require the Indian Stamp Act in order to be enforceable. Although this ruling was legally sound, it made it more difficult for parties to swiftly send cases to arbitration since courts took their time reviewing procedural issues.

Legal Framework for Enforcement of Foreign Arbitral Awards in India

India is a signatory to both the Geneva Convention (1927) & New York Convention (1958). According to Part II of the Arbitration & Conciliation Act of 1996, these agreements lay the groundwork for the implementation of foreign arbitral rulings.

An important case that came before the 1996 Act but is still pertinent is Renusagar Power Co. Ltd. v. General Electric Co. (1994 Supp (1) SCC 644), which defined "public policy" according to the Foreign Awards (Recognition & Enforcement) Act, 1961, which is now a part of the 1996 Act. The Court held that an Indian court could only reject an award from another country on very narrow grounds, such as India’s interests, fundamental legal principles, or ethical or fairness concerns.

There are major procedural and structural disparities between Indian and international practices when comparing arbitration frameworks. The Arbitration and Conciliation Act, 1996, a law derived from the UNCITRAL Model Law, is the principal statute governing arbitration in India. The Act allows the parties to select their own arbitrators, arbitration procedures, and location, highlighting their sovereignty. The selection of arbitrators, interim remedies, and enforcement of awards are some of the restricted situations when court engagement is reserved, as is the goal of judicial intervention minimization. Consistent with international standards, such as recognition under the New York Convention, the Act provides for the enforcement of arbitral rulings. There are still real-world obstacles, though, even with these protections in law.

Arbitration loses some of its value as a quicker alternative to litigation due to judicial delays, unclear procedural requirements, and uneven court interpretations.

Structured procedural frameworks provided by international institutions like the International Court of Arbitration (ICS) and the International Chamber of Commerce (ICC) increase neutrality and predictability. The rules of the ICC and ICS provide for professional case management, set deadlines, and provide thorough instructions on how to submit documents, conduct hearings, and issue awards. Simplified dispute resolution with fewer delays and procedural problems is made possible by specialized tribunals and dedicated secretariats. Furthermore, several jurisdictions have embraced UNCITRAL’s Model Law, which provides a uniform and adaptable framework that helps with cross-border enforceability and reduces disputes about jurisdiction, which in turn boosts investor trust in global trade.

Disparities in institutional backing, openness, and appeal processes are highlighted by the research. International frameworks place an emphasis on swift resolution, enforceability, and expert supervision, in contrast to Indian arbitration, which allows for limited judicial review. As an example, ICC awards are almost never annullable, and the procedures are meant to avoid intervention as much as possible, but Indian courts may step in at various stages, which causes delays. It is worth noting that there is still room for growth in India when it comes to digital arbitration platforms and procedural standardization within international institutions. These measures guarantee openness, effective recordkeeping, and worldwide accessibility.

Bringing local and international practices closer together could be achieved through the integration of digital arbitration platforms, clearer procedural standards, and institutionalized timetables, according to comparative analysis. By bringing Indian arbitration in line with international norms, the country might become a more dependable venue for resolving local and international business disputes, boosting efficiency, enforceability, and investor confidence.

The study examines arbitration in India in comparison to foreign frameworks and finds both its merits and its weaknesses. The dedication of India to bringing its arbitration laws into line with international norms is seen in the Arbitration and Conciliation Act, 1996, which has been strengthened via subsequent reforms. Improvements to procedural delays, support for institutional arbitration, and opportunities for international participation have all resulted from changes made in 2015, 2019, and 2021. A trend towards judicial rulings that limit involvement and respect party autonomy has been developing.

However, there are still real-world obstacles. Efficiency is nevertheless hindered by issues such as enforcement delays, contradictory judicial interpretations, and inadequate institutional capability. The arbitration framework in India is still susceptible to procedural uncertainty, in contrast to foreign systems like ICC and ICSID that offer set timetables, case management, and digital platforms. Additionally, India’s potential to become a global hub is hindered by a lack of knowledge among corporations and an inadequate infrastructure for large-scale institutional arbitration.

As far as enforceability and party autonomy are concerned, the results show that India’s arbitration system is in line with international standards; yet, it is weak in terms of institutional strength, predictability, and settlement speed. These deficiencies can be filled by implementing digital case management, standardized procedures, and stronger institutional structures, which are best practices from global arbitration bodies.

According to the research, India’s arbitration system is now far more in line with global standards, thanks to changes in legislation and the acknowledgement of arbitration-friendly concepts by the courts. Nonetheless, its dependability is nonetheless impacted by ongoing difficulties like as judicial involvement, procedural delays, and underdeveloped arbitral institutions. India has to work on its institutional capacity, its uniformity in judicial interpretation, and its adoption of technological developments in arbitration if it wants to be a competitive centre for international arbitration. India can boost investor confidence, lessen its reliance on litigation, and improve its reputation in international trade by incorporating global best practices while maintaining home safeguards. Both international trade and India’s standing as a major player in the international arbitration arena will be enhanced by a strong, effective, and uniform arbitration system.