中英海事仲裁制度比较

On the comparison of maritime arbitration system between China and UK

围绕仲裁的作用和目的、当事人意思自治原则、仲裁协议及管辖权、仲裁员的资格、仲裁庭与仲裁委员会、仲裁语言等问题,比较中英两国海事仲裁制度的基本特征、原则和做法,分析中英两国海事仲裁的异同及其各自优劣,从而为我国海事仲裁业朝着国际化方向发展提供有益参考。

In order to provide the useful reference for China to develop the industry of maritime arbitration towards the direction of internationalization,this article makes a comparison of basic characteristics,principles and practices of maritime arbitration system between China and UK,further analyzes the similarities and differences between the two countries’maritime arbitration system as well as their respective advantages and disadvantages,centering on the role and purpose of arbitration,the principle of party autonomy,arbitration agreement and jurisdiction,the qualification of arbitrators,arbitral tribunal,arbitration committee and the language of arbitration.