I. Introduction
In the words of Professor Julian D M Lew QC, "National
court involvement in international arbitration is a fact of life as
prevalent as the weather.1 The relationship between
national courts and arbitral process has many facets and has
evolved from being treated by national courts as an inferior
dispute resolution mechanism,2 to a symbiotic one
today.3 This positive change in the national courts
outlook and involvement in arbitration can be attributed to the
progressive legislation in favour of arbitration pursuant to the
adoption of the UNCITRAL Model Law in the national legal
systems.4 Some scholars also define this relationship as
the one that swings between forced cohabitation and true
partnership and also emphasize that the arbitral process relies
upon underlying support by courts, which alone have the power to
rescue the system, when one party seeks to sabotage it.5
The Principle of Judicial Non- Intervention embodied in Article 5
of the Model
