One of the most prominent features of the recent amendment of the French arbitration law is the incorporation into the French Procedure Law, NCPC, of the term juge d’appui («support judge»), which —having originated in Switzerland— had been adopted by French scholars and, more recently, by the French courts. As regards substance, the reform is mostly limited to recording the status quo, by incorporating case law into the Law. However, the reform also includes certain innovations and some surprises, particularly the assignment of universal jurisdiction to the president of the Tribunal de grande instance of Paris in cases unrelated to France when there otherwise would be a risk of denial of justice. This article briefly analyses the background to the reform in respect of the juge d’appui, examines the new set-up in more detail, while comparing and contrasting with Spanish arbitration law and with the UNCITRAL Model Arbitration Law and then concludes with an overall assessment of the reform
Iurgium [previously Spain Arbitration Review]