The substantive law on both domestic and international arbitration in England and Wales is governed by the Arbitration Act 1996 (the “Act”). The Act also applies to Northern Ireland, but not to Scotland. The UNCITRAL Model law, with certain modifications, was given force of law in Scotland by section 66 of the Law Reform (Miscellaneous Provisions (Scotland) Act 1990. In England and Wales (as well as Northern Ireland) the Act significantly improved the law which had hitherto been both confusing and obstructive to modern arbitration practices. The Act embodies most of the best features of the UNCITRAL Model Law.
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