The existence of criminal proceedings, involving facts which are also the subject matter of arbitral proceedings, essentially raises the question as to whether the rule whereby the criminal action takes precedence over civil proceedings (pursuant to Article 4 of the Criminal Procedure Code) must apply and cause a stay of the arbitral proceedings. According to case law on the issue, which can only be approved, the rule applies to domestic arbitration, but not to international arbitration. This is independent of the possibility which the arbitrator has, both in a domestic and an international arbitration, to stay the proceedings until such time as a criminal judgment has been rendered, whether to benefit indirectly from the greater investigative powers of criminal courts, or to avoid the risk of issuing an award which may subsequently appear inconsistent with the findings in the criminal action and therefore contrary to public policy (whether domestic or international).