Dispute resolution in the Arab world is a highly topical subject at present in the aftermath of the Gulf War. Many of the problems of the Middle East stem from breakdowns in the mechanisms for resolving both political and economic conflicts. In spite of a tradition which goes back to the Koran, informal dispute resolution has had an uncomfortable recent history in the Islamic world. Nation states and political groupings have all too frequently found physical force to be the only way to resolve their differences. Others involved in arbitrations with Western businesses have often come away from the experience bitter and aggrieved by the result.

Until the early 1980s, the Arabs were seen by most experts in the West as the “bad boys” of the arbitration scene. Their arbitrators acted as advocates for those that had appointed them (the Buraimi case), they failed to appear (the Libyan nationalization cases) or they simply never paid awards made against them. More recently there has been a perceptible change. Strangely, in view of recent events, it was the Kuwaiti Government in its impeccable behaviour during the Aminoil case which did much to improve the reputation of Arab governments in this area. Currently, those with experience of arbitrations involving Moslem states have diminishing numbers of horror stories to tell. It is still true, though, that Western parties will avoid arbitrating in the Arab world whenever possible. They are suspicious of the possibilities of meddlesome courts, unfair procedures and restrictions on their ability to appoint non-Moslems as arbitrators.

Against this background, Arab lawyers are starting to explain their arbitration laws and traditions to a curious Western audience. Until recently, Salim Saleh’s book, Commercial Arbitration in the Middle East (Graham & Trotman, London, 1984) was the only major title in a Western language to give a full account of the laws of the Arab world. Now Dr El-Ahdab, a Lebanese lawyer currently working in France, has sought to fill this vacuum. His book, Arbitration with the Arab Countries, first appeared in French. It consists of a number of parts. First, the author describes the approach of the various Islamic schools to arbitration. He then presents overviews of French, English, U.S. and “socialist” arbitration laws. The main body of the work consists of an account of the law of each of the Arab countries. The last part of the book contains essays on arbitration concerning foreign investment in the Arab world and institutional dispute resolution. It concludes with arbitral awards involving Arab parties and English translations of arbitration statutes in the region.

The book is overlong, poorly translated and extremely difficult to read. (Take, for example, the opening sentence of Part II on Saudi Arabia: “A constitutional experience had marked the beginnings of the Kingdom.”) The opening section on the Islamic approach to arbitration ought to be quite fascinating. It is marred, however, by irrelevant detail, poor structure and awful translations of the Koran.

Since this book is presumably aimed at a Western audience, the part on non-Islamic laws should have been excluded. It adds nothing new except an erroneous criticism of the French Cour de Cassation’s decision in the Pabalk case. (Whatever one thinks of the merits of the French legislature’s omission of the setting aside of an award in its place of origin as a ground for refusing enforcement, the Cour de Cassation’s application of Art. VII of the New York Convention was immaculate.)

The sections on the individual Arab countries all follow a format. There is a brief overview of the history and workings of each country’s legal system, followed by a description of the relevant law under a number of standard headings. Little criticism is proffered. Where the law is unclear, the author has either not mentioned the issue or simply quotes the obscure statement of law which is the source of the problem. Consequently, different questions of