Comparison of international arbitration law and UNCITRAL model law

ABSTRACT 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards is an important progress taken in international commercial area. As a reason of developments in international commercial law, a technically competent association in this field and an endeavoured new organ, a commission for international Trade law, needed to be created - 1966 United Nations Commission on International Trade Law - UNCITRAL. UNCITRAL created a model law, for harmonization and improvement of national laws, which can be adopted by all countries. Some of the countries had totally adopted the Model Law, some which already have a law on this subject had modifications. New York and Geneva Conventions facilitated the recognition and enforcement of foreign arbitral awards. But it was still continuing the international arbitration, which took place in Turkey, should be convenient under the mandatory rules of Turkish Civil Procedure Law. A regulation, in order to prepare conformable conditions for international arbitration, to save the disputes arising from international commercial relations from the restricting provisions of domestic law, in detail to expand the quota of Turkey in arbitration market, on 21st of June 2001, with the number of 4686, International Arbitration Law accepted before the example of UNCITRAL Model Law. In this study, the provisions of International Arbitration Law, the similarities and the differences between this Law and UNCITRAL Model Law tried to be explained. VI