Document production in international arbitration—a practical guide

Produced in partnership with Courtney Lotfi of Jones Day

Practice notes

Document production in international arbitration—a practical guide

Produced in partnership with Courtney Lotfi of Jones Day

Practice notes

This Practice Note provides practical guidance on document production in international arbitration proceedings. It addresses the two main forms of document production that arise in international arbitration:

•
the production of documents in response to a request for production (or request(s) to produce), and
•
the voluntary production of documents associated with the parties’ written submissions, including their pleadings ((statements of case), witness statements and/or expert reports)

Since each arbitration is different, practitioners should consider any particular features of their case that may have a bearing on document production.

Reference is made throughout this Practice Note to soft law and arbitration rules which may inform or illustrate the process of document production as it takes place in many arbitrations, with particular focus on the IBA Rules on the Taking of Evidence in International Arbitration (the IBA Rules). It reflects the recent version of the IBA Rules, which were promulgated in December 2020.

The following related Practice Notes may also be of interest to practitioners:

•
The role of documentary evidence in arbitration
•
Disputes

Jurisdiction(s):

United Kingdom

Key definition:

International arbitration definition

What does International arbitration mean?

Generally, arbitration with features relating to two or more states. For example, an arbitration seated in London between an English company and a Singapore company concerning a construction project in London (or elsewhere) will generally be considered an international arbitration.

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