Name
Two traditions, one tribunal: navigating the common law – civil law divide
Date & Time
Friday, October 23, 2026, 1:10 PM - 2:10 PM
Speakers
Sae Youn Kim, Kim & Chang
Domitille Baizeau, Hong Kong International Arbitration Centre
Zhou Yarui, Tahota
Domitille Baizeau, Hong Kong International Arbitration Centre
Zhou Yarui, Tahota
Description
While Hong Kong and Singapore are the two largest arbitration hubs in Asia, much of the region consists of civil law jurisdictions. With disputes increasingly involving participants from both civil law and common law backgrounds, how can counsel manage procedural differences? This panel will explore practical ways to bridge cultures, drawing on real‑life experiences and solutions in Asia.
The panel are expected to discuss:
- Key procedural flashpoints between civil law and common law approaches, including document production, witness examination and tribunal involvement
- How tribunals can adapt procedures to create an even playing field for parties from different legal cultures
- Privilege: a practical example of bridging legal traditions? How have common standards been established?
- Is procedural harmonisation desirable?
Session Type
Fireside Chat