Key legal question
Whether the arbitral tribunal was irregularly composed because one arbitrator was not sufficiently consulted in the final deliberation
Extracted holding
The deliberation procedure was regular; the minority arbitrator had the opportunity to participate and, at minimum, tacitly accepted the written continuation of the deliberations.
Extracted reasoning
The tribunal combined oral and written deliberations, which is acceptable in international arbitration. The minority arbitrator received successive drafts and could have reacted immediately after the final draft and ICC approval, but did not do so.