The impact of uncitral model law in some domestic legal systems : a comparative study between England and Libya

الملخص EN

International commercial arbitration represents a prominence in the field of international trade contracts where day by day it bccomcs the most used method to resolve disputes that may arise between parties to such contracts.

In this respect this research focuses on the impact of UNCITRAL Model Law due to the vital rule that this Model Law plays in the field of international trade contracts and to the impact of such Model Law into domestic legal systems.

Such study is important since the UNCITRAL Model Law has been adopted by great number of countries globally.

The main conclusion drawn from this study is that although the criticism that has been directed to the UNCITRAL Model Law, such Model Law still has an important impact into domestic legal systems, due to the fact that countries did not adopt the model law have at least given sufficient consideration to the Model Law while drafting their arbitration laws or having their arbitration acts based on the UNCITRAL Model Law by adopting the structure and language of this Model Law.