عنوان مقاله [English]
The arbitral awards are final and binding yet may be challenged before national courts. Generally, the extent and scope of judicial review and reasons that seek to set aside the award are determined in the national law of the parties or international instruments. Is this agreement valid if the parties change the scope of judicial review by the national courts? Depending on whether this change is related to exclusion, limitation or extension of judicial review, legal systems have different approaches. Except in cases where the agreement of the parties is contrary to public order, in other situations the free will of the parties must be respected. New approaches on the initiative of the parties in the administration of proceedings and the contractualisation of justice reinforce this doctrine.