Describe the primary alternative approaches to reviewing arbitration awards, and discuss ways those alternatives might be more or less desirable than the approach taken in Fidelity Management SA v Myriad International Holdings?

Arbitration has become an incredibly common and popular tool for parties who wish to resolve commercial disputes. Along with the lex mercatoria, arbitration has geographical benefits in that it circumvents the need for foreign parties to litigate in, what to them would appear, a foreign court within a foreign jurisdiction. [1] Arbitration is popular as it gives the disputing parties optimal control, not only can the choose the body or persons to arbitrate, but they can also elect where this arbitration is to take place. [2] The speed of such arbitration, notable from the WTO selection of arbitration as a dispute settlement mechanism, makes it even more attractive for commercial parties. [3] The case of Fidelity Management SA v Myriad International Holdings [4] was followed by an even more significant decision in the House of Lords – the case of Lesotho Highlands Development Authority v Impregilo SpA. [5] Both of these cases significantly state that English courts are not to inte