Jurisdiction(s):
United Kingdom

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Key definition

UNCITRAL Model Law definition

What does UNCITRAL Model Law mean? In practice, UNCITRAL model Law refers to the UNCITRAL Model Law on Cross‑Border insolvency (1997), a template used to recognise and assist foreign insolvency proceedings and to coordinate concurrent cases in different countries. It is not legislation itself; it is a non‑binding model text produced by UNCITRAL and adopted into domestic law by states. In England & Wales and Scotland it is implemented by the Cross‑Border Insolvency Regulations 2006 (CBIR 2006), and in Northern Ireland by the Cross‑Border Insolvency Regulations (Northern Ireland) 2007. Key features include: access for a foreign representative to apply to the court; recognition of foreign...

Mauritius international arbitration: International Arbitration Act 2008 (Model Law based), PCA appointments, Supreme Court support and Privy Council appeal, tribunal powers, awards and enforcement, and optional opt-in provisions

Published by a LexisNexis Arbitration expert

Practice notes

Mauritius operates a mixed legal framework, blending French civil law with British common law traditions. It features a dual structure: procedure in criminal and civil litigation is largely English, whilst substantive norms draw on the French Napoleonic Code.

The system bears hallmarks of both civilian and common law, adapted to local needs to forge a distinctive body of Mauritian law. This is evident in the separate regimes governing domestic and international arbitration.

Domestic arbitration provisions are set out in the Civil Procedure Code 1808 (Code de Procédure Civile) (CPC), while international arbitration is regulated by the International Arbitration Act 2008 (IAA 2008), which is modelled on the UNCITRAL Model Law on International Commercial arbitration.

This Practice Note should be read alongside the Practice Notes: Arbitration in Mauritius—an introduction and Enforcing arbitral awards in Mauritius.

Basis of the IAA

Experience in other countries shows that applying the same Rules to both domestic and international arbitration can create tension between a more interventionist approach in the domestic sphere and the contrasting non‑interventionist approach...

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Web page updated on 21/05/2026

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