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LMAA & SCMA ARBITRATION – A COMPARATIVE APPROACH

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Drawing it all together: Conclusions<br />

(C)<br />

• <strong>LMAA</strong> Terms and <strong>SCMA</strong> Rules are similar in many<br />

respects. Both provide for “ad hoc” arbitration.<br />

• <strong>LMAA</strong> Terms and <strong>SCMA</strong> Rules both emphasise the<br />

parties’ freedom to choose/decide and provide a<br />

wide discretion to the arbitral panel.<br />

• <strong>LMAA</strong> places a greater reliance upon the provisions<br />

in the standard model law arbitration clause (for<br />

example inclusion of Small Claims/ Intermediate<br />

Claims Procedures).<br />

• Default number of arbitrators now the same.<br />

• Rights of appeal from awards are materially different<br />

where the arbitration is “International”.

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