Complementarity or disparity?

Interest in the use of arbitration as a mechanism for resolving commercial disputes has grown tremendously in the last two decades. This growth could be credited to the awareness by national governments and international bodies to change the culutre of strict litigation and allow parties some autonomy in resolving their disputes. Both UNCITRAL Law Internatinal Commercial Arbitration and English Arbitration Act 1996 have changed disputing-resloving culture in business environment. This article revisits the relationship of these two systems of arbitration and examines the extent they have contributed to the development of use of arbitration across different commercial terrains