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Boston University School of Law




Fans of the Alexandre Dumas novel Three Musketeers will remember that the adventure includes a fourth young man, d'Artagnan, who hopes to become one of the King’s guards, along with his friends Athos, Porthos, and Aramis, living by the motto “All for one, one for all”. Likewise, an arbitrator’s generally includefour key obligation: accuracy, fairness, and efficiency, as well as vigilance in promoting an enforceable award. Prevailing litigants normally hope that the arbitral process will lead to something more than a piece of paper. To this end, they expect arbitrators to avoid giving reasons for annulment or non-recognition to any authority called to review the award. Two judicial decisions, one in France and the other in the United States, highlight the complex interactions among these duties. In both instances, arbitral awards were vacated for failure to balance competing duties in the manner desired by the reviewing judges.


Published as: "The Four Musketeers of Arbitral Duty: Neither One-For-All nor All-For-One," 8 ICC Dossiers 25 (2011). Adapted from the French: "Les devoirs de l’arbitre: ni un pour tous, ni tous pour un," 2001 Cahiers de l’Arbitrage 13 (2011). Revised 8 Revista de Arbitragem E Mediação 117 (A. Wald, São Paulo, 2011).

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