How should an international arbitrator interpret the rules of immediate application? Are they solely bound by the law chosen by the parties, or must they consider mandatory rules of the seat, the country of performance of the contract, or third legal orders with a substantial connection to the dispute;

When can the non-application or improper application of such a rule lead to annulment or refusal to recognize the arbitration award;

What are the true boundaries between private autonomy and state imperativeness in international commercial arbitration;

The work approaches the rules of immediate application not merely as exceptions to the applicable law but as a privileged area of intersection between private international law and international arbitration. Through systemic analysis, on the one hand, of the state control over the arbitral award via arbitrability and the filter of international public order, and on the other, of the internal methodology of arbitral decision-making, focusing on the evident, active, and specific breach of international public order, it is argued that imperativeness is not applied mechanically but as part of a controlled, justified, and proportionate balancing.

It is addressed to legal professionals, arbitrators, judges, academics, and students who wish to gain an in-depth understanding of the position of mandatory rules within the modern multi-centre judicial environment in which international commercial arbitration is embedded.