The decisions of arbitral tribunals are more and more known, and are frequently cited and analysed. There is no doubt as to the usefulness of such a body of reported decisions, since this provides greater certainty. Nevertheless, the manner in which this is generated differs from that of national Courts, making it less predictable. Its development is also influenced by the substantive issues concerned. Even if it performs more or less the same function as the body of case law generated by national Courts, “arbitral jurisprudence” is more particularly dependent on the proximity between the arbitrators and the rules applicable to the merits of the dispute.