عنوان مقاله [English]
Arbitration is a private justice for the settlement of disputes in the international trade. By reason of number of benefits, international traders prefer the arbitration in relation to the justice tosettle their disputes. Confidentiality is one of those benefits. Here, there are some questions: is there any source in international commercial judgment that indicates the confidentiality of judgment? And what are the scope & the sanction of this obligation? Comparative study of international commercial law shows that they don’t have unified approach for the existence or source of this obligation. In fact proving this obligation in the absence of explicit agreement between the beneficiaries is a major problem. Some legal systems, this obligation is denied. In this article, it’s attempted to demonstrate this obligation as an implicit condition of contract and to specify the sanction.