Title Page
ABSTRACT
Contents
CHAPTER I: Background and Introduction 11
1.1. Historical Background 11
1.2. Introduction of Third Party System under International Commercial Arbitration 14
1.2.1. The Definition of International Commercial Arbitration 14
1.2.2. The Definition of Third Party 16
1.3. The Arising of the Third Party Problem 17
1.4. Practical Significance of the Third Party System 21
CHAPTER II: The Development of Third Party System under International Commercial Arbitration in States 26
2.1. The Development of Third Party System in Netherlands 27
2.2. The Development of Third Party System in Belgium 30
2.3. The Development of Third Party System in France 33
2.4. The Development of Third Party System in England 35
2.5. The Development of Third Party System in America 37
CHAPTER III: The Development of Third Party System under International Commercial Arbitration in International arbitral institutions 41
3.1. The Development of Third Party System in Arbitration of the International Chamber of Commerce (ICC) 42
3.2. The Development of Third Party System in Arbitration the London Court of International Arbitration (LCIA) 49
3.3. The Development of Third Party System in Swiss Rules of International Arbitration(SCAI) 53
3.4. The Development of Third Party System in American Arbitration Association International Dispute Resolution Procedures 57
CHAPTER IV: The Development of Theories of Third Party System 61
4.1. Arbitral Estoppel 61
4.1.1. Arbitral Estoppel in Theory 62
4.1.2. Arbitral Estoppel in Practice 64
4.2. The Group of Companies Doctrine 69
4.2.1. The Group of Companies Doctrine in Theory 69
4.2.2. The Group of Companies Doctrine in Practice 74
CHAPTER V: The Third Party System in China 77
5.1. The Introduction of Third Party System in China's Domestic Commercial Arbitration Context 77
5.2. The Development of Third Party System in the China International Economic and Trade Arbitration Commission(CIETAC) 82
5.2.1. 2012 CIETAC Rules 82
5.2.2. 2015 CIETAC Rules 84
5.3. Perfecting of the Third Party System in China's International Commercial Arbitration Context 87
CHAPTER VI: Conclusion 90
REFERENCES 92