This book contains a comparative study of the rules governing the formation of arbitration agreements under Danish, English and Norwegian law. The relevant domestic legislation and international treaties, such as the New York Convention 1958, are considered in detail. The book deals with general rules of arbitration and contract law as well as distinct transport law rules. The central element of the book is the criteria which must be satisfied before a party is obliged to arbitrate a given dispute, however, also certain elements of arbitral procedure, such as the principle of Kompetenz-Kompetenz, are discussed. Of particular interest to the transport lawyer is the book's examination of the arbitrability of transport disputes under the international transport law conventions. The Nordic regime introduced in the new Nordic Maritime Codes of 1994, and the compatibility of the requirement for writing in the New York Convention 1958 and the documentation presently used in maritime transport.
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