PROCEDURAL AND SUBSTANTIVE GROUNDS FOR THE ANNULMENT OF ARBITRAL AWARDS IN VARIOUS LEGAL SYSTEMS

The purpose of the study is to analyze the procedural and substantive grounds for the annulment of arbitral awards in Russia, France, Great Britain and Singapore as states belonging to different legal systems. The author examines the judicial practice of these states, as well as analyzes the doctrine regarding the interpretation of the grounds for annulment provided for by national laws on international commercial arbitration. Based on the results of the analysis of judicial practice, the author came to the conclusion that states seek to actively develop the institution of arbitration and interfere in its activities only in exceptional cases. The paper also examines the grounds for annulment, enshrined in international legal acts governing arbitration issues. They are reduced to jurisdictional or processual (procedural) violations of arbitration proceedings (procedural grounds), but not violations of applicable substantive law (substantive grounds). At the same time, each state independently determines the list of grounds for the annulment of arbitral awards in national laws, taking into account those grounds that are enshrined in international acts. For example, Russia adopts these grounds almost completely, the United Kingdom and Singapore establish a more expanded list of them, and France, on the contrary, is more limited.