A. Introduction

5.1 The principles of the “conflict of laws” (sometimes described as private international law) determine which system of law governs a particular legal problem, and which forum should decide a dispute. These principles are sometimes of particular relevance in maritime arbitration which, by reason of its international nature, may give rise to disputes as to which law governs a particular issue and which tribunal should decide it. These disputes are of practical importance since different systems of law (or tribunals) will often give rise to different outcomes. This chapter aims to set out the basic principles determining the law applicable to disputes relating to arbitration. Reference to specialist works such as Dicey, Morris & Collins on the Conflict of Laws is recommended for greater detail.