A Comparative Study of the Commercial Arbitration System between the International System and the Islamic System

This paper examines arbitration in both international and Islamic commercial law frameworks, providing an in-depth analysis of arbitration as a dispute resolution mechanism. The first section introduces the concept of arbitration, including its definition, history, and various terms. It explores major international arbitration centers like the ICC, LCIA, and ICSID, highlighting their role in global dispute resolution. The second section delves into international commercial arbitration, discussing key conventions and arbitration rules, particularly the UNCITRAL guidelines. The third section shifts focus to Islamic commercial arbitration, analyzing its principles, notable arbitration centers, and how Islamic law influences arbitration procedures. The paper concludes by comparing international and Islamic arbitration systems, identifying common challenges and benefits in their application.