State immunity as defense against enforcement of international investment arbitral awards: A pursuit to remedy the Achille's Heel of investor-state arbitration
Date of Publication
5-2018
Document Type
Master's Thesis
Degree Name
Juris Doctor
Subject Categories
International Law
College
College of Law
Department/Unit
Law
Thesis Adviser
Anacleto Rei A. Lacanilao III
Abstract/Summary
This study assesses the effect of the invocation of state immunity as a defense by a respondent-State against execution of arbitral award. The research reveals that, a successful investor in investment arbitration might have obtained a muted victory when the respondent-State raises the State immunity defense as a ground to preclude the attachment of its assets during the enforcement of the award. And this poses as a legitimate concern because of the failure of the enforcement vehicles to address the conflict. Despite the proenforcement development of the ICSID and New York Convention, they refer execution to the national laws of the place where execution is sought. Furthermore, notwithstanding the employment of the restrictive theory of immunity by many States, the investor bears the great burden to locate State assets suitable for attachment, and would have to prove that the suitability is in line with the national law of the forum State, which was proven to be very tedious and difficult as respondent-State may not only remove its assets within the jurisdiction of the court, but may also tag them as privileged properties, unless the property in question is clearly designated to be commercial. Therefore this study aims to develop a Guideline, based on the solutions proposed by the experts in the field, that ensures execution without impairing the rights and interests of the respondent-State and for the latter to attract even more investments, since total preclusion of invocation of the state immunity from execution is impossible.
Abstract Format
html
Language
English
Format
Electronic
Accession Number
CDTG007487
Shelf Location
Archives, The Learning Common's, 12F Henry Sy Sr. Hall
Physical Description
1 computer optical disc; 4 3/4 in.
Keywords
Immunities of foreign states; Arbitration (International law); Investments, Foreign—Law and legislation
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Recommended Citation
Dado, K. M. (2018). State immunity as defense against enforcement of international investment arbitral awards: A pursuit to remedy the Achille's Heel of investor-state arbitration. Retrieved from https://animorepository.dlsu.edu.ph/etd_masteral/7235
Embargo Period
11-25-2024