Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

International arbitration definition

What does International arbitration mean? International arbitration describes an arbitration with cross‑border elements, typically where the parties are in different states, the agreed seat or place of performance is abroad, foreign law governs, or enforcement will be against overseas assets. In practice it refers to international commercial arbitration under an arbitration agreement. In England & Wales, Scotland and Northern Ireland it is a descriptive term rather than a statutory category; neither the Arbitration Act 1996 nor the Arbitration (Scotland) Act 2010 defines it. In Ireland, the Arbitration Act 2010 gives UNCITRAL Model Law force of law; Article 1(3) sets out when an arbitration is “international”...

International arbitration document production: strategy, requests to produce and Redfern Schedules, e-disclosure, privilege, confidentiality, third-party documents and tribunal orders under the IBA and Prague Rules

Published by a LexisNexis Arbitration expert

Practice notes

This Practice Note offers practical guidance on managing document production in international arbitration proceedings. It covers the two principal pathways by which documents are produced:

the production of documents in reply to a request for production (or request(s) to produce),
the voluntary production of materials accompanying the parties’ written submissions, including their pleadings (statements of case), witness statements and/or expert reports.

As every arbitration differs, practitioners should assess any case-specific features that may influence document production.

Throughout, it refers to soft law and arbitration rules that can inform or illustrate how production commonly occurs, with particular emphasis on the IBA Rules on the Taking of Evidence in International Arbitration. It reflects the latest version of the IBA Rules, issued in December 2020.

Related Practice Notes of interest include:

The role of documentary evidence in arbitration
Disputes over documentary evidence in arbitration
Evidence in international arbitration—the IBA Rules on the Taking of Evidence in International Arbitration
Electronic evidence in arbitration

What is

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Courtney Lotfi

Courtney Lotfi ADR Consulting GmbH

Courtney Lotfi focuses her practice on international arbitration and dispute resolution and has broad-based experience in the energy, construction and industrial engineering, life sciences, automotive, aerospace, and technology sectors.Courtney began her international arbitration practice at Freshfields, where she represented a European energy company in a series of market-leading arbitrations, including a prominent price review arbitration resulting in the tribunal rewriting the purchase price formula for natural gas under a long-term, large-volume supply contract and a take-or-pay arbitration concerning the validity of certain contractual off-take provisions under EU competition law.More recently, Courtney led or co-led the representation of Belgian and Hungarian energy companies in a post-M&A ICC arbitration with a Swiss energy company related to the sale of a coal-fired power plant; an international consortium in another ICC arbitration stemming from the construction of a liquified natural gas (LNG)...

Web page updated on 21/05/2026

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