Asian International Arbitration Journal

Volume 15 (2019)

Volume 15 (2019) / Issue 2

Sarah Alshahrani, 'Ousting choice of law in international contracts: lessons from aramco case' (2019) 15 Asian International Arbitration Journal, Issue 2, pp. 119–132


This article examines the landmark Aramco case from a different perspective. It is not focusing on the outcome of the award, as the Saudi government lost this case and consequently prevents any arbitration against the government. Alternatively, this article focuses on ousting Islamic law as the choice of law clause. It thoroughly examines the argument favouring the “internationalisation” of contracts to prevent the application of the host state’s law of developing states. The tribunal decision bears many lessons worth nothing.

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ISSN: 1574-3330
ID: AIAJ2019008