The determination of the appropriate scope of review of arbitral awards has presented jurists with complex challenges ever since the days of Ancient Rome.1 The history of annulment proceedings before the International Centre for Settlement of Investment Disputes (ICSID) goes back to the 1980s. Many heated debates have taken place since then, questioning the efficiency and legitimacy of the internal review mechanism provided under the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (the ICSID Convention). Professor...
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