Arbitration in different countries --- Yes it differs, take for example a country like South Africa, it enacted the Protection of Investment Act in 2015, which is in line with the country's constitution. Even though the Act permits the government to consent to international arbitration, that only happens after the investor has exhausted all domestic remedies. Also, South Africa and the investor's home state have to agree to conduct the international arbitration, and the international arbitration, is seen as being between the two states and not between South Africa and the investor.

Source author: Matshedisa Emily Mokoena mokoenamati@gmail.com