REVIEW OF RELATED LITERATURE
This chapter shall be discussing the findings of related researches to this study. It shall provide a discussion on the significance of this study to the existing literature. The contents of this portion of the study is gathered and collated from its secondary data.
International Commercial Arbitration
Arbitration is a device whereby the settlement of a question, which is of interest for two or more persons, is entrusted to one or more other persons, the arbitrator or arbitrators, who derive their powers from a private agreement, not the authority of a State, and who are to proceed and decide the case on the basis of such an agreement.[1] Moreover, arbitration has also been defined as a mechanism for the settlement of disputes between parties, either by a person appointed by themselves or by relying upon procedures or institutions chosen by the parties.[2] In his definition of arbitration, Robert highlights the similarity between arbitration and litigation: “Arbitration means instituting a private jurisdiction by which litigations are withdrawn from the public jurisdictions, in order to be resolved by individuals vested, for a given case, with the powers to judge such litigations.” [3]
Based on the definitions stated above, it is thus possible to outline the certain essential attributes of arbitration. One of the cornerstones of arbitration, which also serves as a semblance of an interim protection, is its consensual nature.[4] The power and jurisdiction of arbitrators are determined by the intention of the parties as reflected in their contractual agreement. Thus, the wording of the arbitration agreement circumscribes the scope of an arbitrator’s power.[5] The cordial nature of arbitration has led one writer to contend that arbitration is a private system of adjudication and that it is the parties, not the State, that control the powers and duties of arbitrators. [6]This view is accurate to the extent that it underlines the private character of arbitration. However, it is misleading in suggesting that parties to arbitration have the exclusive right to assign powers and duties to the arbitrators. Although arbitration is essentially a private process, the assistance of national legal systems is in some cases sought to assist the arbitration proceedings or to enforce an ensuing award. Furthermore, the effectiveness of the arbitration process is guaranteed by the assistance of national courts. [7] There are different perspectives on how to view arbitration. To illustrate, one perspective is the contractual theory emphasizes the contractual nature of arbitration. The jurisdiction and powers of an international arbitrator are, as noted above, dependent on the mutual intention of the parties as reflected in their agreement, and without their agreement there can be no valid arbitration. Another perspective is the jurisdictional theory focuses on the authority of a State to regulate all arbitrations conducted within its territory. The theory maintains that the validity of the arbitration agreement, the powers of the arbitrators, and the enforcement of the arbitral award all derive from a particular national legal system.[8] In this sense, arbitration cannot be carried on without the regulation of a national legal system.[9] Similarly, another view is the mixed or hybrid theory recognizes the dual influence that defines the nature of arbitration. As its originator, G. Sauser-Hall, points out, “although deriving its effectiveness from the agreement of the parties as set out in the arbitration agreement, it arbitration has a jurisdictional nature involving the application of the rules of procedure.”[10] Moreover, another concept is the autonomous theory of arbitration insists that arbitration should be viewed in a broad context: rather than emphasizing the structure of the institution, emphasis should be placed on its goals and objectives. A complete picture of arbitration can only be presented by considering its use and purpose, and the way in which it responds to the needs of the business community.[11] The theories of arbitration discussed above shed light on the various and often contradictory demands that influence the arbitration progression. A contractual theorist would necessarily advocate unhindered party autonomy, whereas a jurisdictionalist would argue for substantial judicial supervision of arbitration. An adherent of the mixed or hybrid theory is likely to favour an effective mixture of autonomy and regulation, whereas an autonomist would focus on what is necessary to ensure that arbitration meets the needs and objectives of the parties. In the end, each legal system must struggle to reconcile these conflicting interests. As argued above, no one approach is entirely satisfactory. Each represents a way of looking at arbitration. A fuller and richer view must, of course, contemplate its object from all possible perspectives. In this regard, the law should reflect a blend of the above theories so as to ensure that arbitration meets the larger needs of society. The mixed or hybrid theory meets this objective by focusing on both the contractual and the jurisdictional basis of arbitration. This theory cautions us always to remember that international arbitrations cannot be entirely divorced from the legal systems with which they come into contact. For as Robert and Carbonneau (1983) prompts, “the validity of arbitral adjudication is directly dependent upon the recognition by the legal system that the arbitral process responds to the felt needs of society.”[12] The fact that the process of arbitration at some point draws assistance from national legal systems suggests that the latter could demand and ensure that the arbitration process meets minimum standards of fairness and justice. One way of ensuring this is by imposing on arbitrators a positive duty to maintain due process in the conduct of arbitrations, a duty that is indirectly enforced by national courts refusing to enforce awards made by arbitrators who do not follow due process in the conduct of arbitration.[13] It is therefore misleading to suggest that parties to arbitration have exclusive right to assign the powers and duties of arbitrators. However, the point should be made that, unlike litigators before a national court who have very little control over the judge’s powers and duties, parties to an arbitration, together with the relevant national legal systems, regulate the powers and duties of arbitrators. Moreover, arbitration is also characterized by the fact that the parties themselves appoint the arbitrator. The parties may delegate this responsibility to an arbitration institution.[14] Equally, they may select a few arbitrators and mandate them to appoint other arbitrators. The parties to arbitration also determine the procedure to be followed in the conduct of the arbitration. They may do this by enumerating detailed procedural rules as part of their arbitration agreement or by adopting the in-house rules of an established arbitration institution, such as the International Chamber of Commerce. It is disputed to what extent they can exclude certain procedural rules of the place of arbitration, especially those that are considered mandatory.[15] Another important feature of arbitration is that awards made by arbitrators, in contrast to the decision or recommendations of conciliators and mediators, are binding on the parties. Arbitrators perform the “judicial function” of settling the parties’ dispute based on their determination of the rights and obligations of the parties. Under narrowly defined situations, international arbitral awards could be appealed against in appropriate courts. In handling international arbitrary disputes, the United Nations Commission on International Trade Law (UNCITRAL) is among the major players by formulating a universal model law that if enacted by member countries of the United Nations would modernize and harmonize the law relating to international commercial arbitration. UNCITRAL is the “core legal body within the United Nations system in the field of international law, with a mandate to coordinate legal activities in this field in order to avoid duplication of effort and to promote efficiency, consistency and coherence in the unification and harmonization of international trade law.” (UNGA Res. 40/71) Advantages of Traditional Commercial Arbitration
In the international arena, the advantage of arbitration over litigation as a method of dispute resolution is no longer subject to debate. One reason for this trend is that private international arbitration agreements allow parties to draft provisions suited to their particular needs in anticipation of future disputes.[16] Indeed, arbitration agreements are in essence a type of forum selection agreement that attempts to avoid many of the problems related to jurisdiction.[17] Such problems range from whether a court has jurisdiction over the defendant.[18] to the unattractiveness of disputing or attempting to enforce a judgment in the other party’s country, where the tribunal may be more inclined to favour its own nationals.[19] In other words, international businesses have a strong incentive to avoid the local bias that may be faced when arguing a dispute in the courts of other countries. Arbitration also provides flexibility, speed, and financial savings in international disputes, whereas litigation can be slow and costly.[20] Arbitration also foregoes the need for a judge and the accompanying formal proceedings. Instead, the parties agree on an impartial third person to act as arbitrator.[21] Typically the arbitrator is more informed than judges or juries about the subject of the dispute and the customs of the industry and can preside over the proceedings without formal procedural requirements, such as rules of evidence, which often create an overly adversarial environment.[22] Thus, the increasing use of international arbitration, when conducted under the auspices of an arbitral institution,[23] shows that “privatised rulemaking” can, at least in the area of comparative law, serve as a practical tool to the international commercial community.[24]
The primary incentive for international arbitration is its uniformity, economy, and speed. The advantages of being able to control the proceedings in international arbitration by being able to, for example, contribute to the choice of an arbitrator(s) without worrying about the sympathies of that person clearly make arbitration preferable over having to litigate in a foreign state. These advantages, however, require the assistance of two countervailing forces. First, to achieve efficiency and economy, international arbitration must avoid systems of control that would come to resemble domestic courts, with their backed-up dockets and their protracted proceedings. Second, without a mechanism to insure uniformity, to avoid to pitfalls of localization of rulings, a system is required to insure not only appeals, but to ultimately gain the trust of the international commercial community.
Gaining an award is not the final step in the arbitral process. The assistance of national courts is needed for enforcement of arbitral awards. Without their assistance in either enforcing an award against a party or offering their protection against the potential compromise of rights and abuse, the arbitral process would present far less assurance to the international commercial community. The two recent cases discussed in this Comment illustrate these points, while also pointing out some of the potential problems with the present judicial interpretation of the Convention.
Another advantage of traditional arbitration is the ability to choose a forum in a “neutral” third country. Worldwide commerce involves specific demarcation of other countries and while there is a great interest in increasing such trade the individuals involved are wary of getting involved in legal battles in their counterparts countries. The preference to circumvent legal actions in a different country need not have to stern from the idea that the said courts are inadequate. There is a feeling of being disadvantaged when having to deal with foreign customs (legal or other), foreign location and maybe even a foreign language. The feeling of hindrance is elevated by the reality that the adversary is completely competent in these environments. Thus arbitration in a third non-aligned nation may have in an increased sentiment of even-handedness. The advantages of a virtual tribunal are that all the parties are located on home ground. The disadvantages, which may occur from ones opponents’ technical skill, can be avoided by bringing in local experts.
Similarly, arbitration also provides procedural swiftness. Notionally placing an arbitration stipulation denotes that all disagreement curtailing from that bond are resolved in arbitration as a replacement for of civil courts. This implies that the tangible proceedings come to pass at a period established upon by the parties and the subject is settled without delay and tranquilly.
Another great advantage of arbitration is part autonomy. Since the factions have liberally selected to eliminate the civil court proceedings from the management of their agreement they are also unbound to choose which laws or principles should be the guiding principle for the arbitrator when mulling over the disagreement. Arbitration permits the factions to decide which countries principles they want to utilize to the dispute. It can go so far as to divide substantive laws from technical laws by decide on them from different countries. This is perceptibly unfeasible in civil courts where the law utilized is the local court’s treatment of private international law. It is this great autonomy of choice that will consent arbitration to assume the steps compulsory to enter the virtual arena. Since arbitration is such an adaptable technique of dispute resolution the contracting factions frequently make an effort to keep a tight rein on future confusion by referring to the system and measures of an arbitration institute. By doing so they concur to adhere to the regulations for arbitral proceedings of that institute. The arbitrator has the independence to reduce to bare bones or set hurdles on the process at the appeal of the factions but it is not constantly in the concern of both parties to shorten the proceedings.
In addition, the advantages of arbitration are often said to be found in its cost efficiency. The tribunal is seen as a complementary to the costly courts. Nevertheless, this might be a mistaken belief. The use of courtrooms do not equal to any amount of money, it is more of the expenses for retaining lawyers to claim a case in the varied courts in anticipation of the moment that the case arrive at the highest court and the case cannot be appealed any further, or one side gives up. The image of a disagreement being hauled through the courts over a interlude of countless years is sufficient to make most capitalist give further details about the merits of arbitration. The actual process is the most certain source of costs in arbitration. Under this are the arbitrators’ fee and the fee to the institute, lawyers’ fees and travel and living expenses. However, the merit of the process is that the decision of the tribunal are final and cannot be appealed to thus the process becomes brief which in turn minimize the total costs.
Similarly, another advantage is the prevention of public access of proceeding records since it is not done in court. Nevertheless, this is dependent on the prerogative of the parties in their respective silence. Moreover, added sentence can be charged on the faction infringing the silence though it may be difficult to prove. The predicament opposite online arbitration is the concept of confidence. The factions must be able to depend on the security of the system of communication. The lack of probability for any unofficial individual to acquire admission to the information dispatched to the arbitration institution. The fortification of communication lines of both parties as well as the information inventory is of principal significance to the warring factions as well as the repute of the arbitration institute.
Furthermore, although the litigation in courtrooms can be an effective tool along with its formal procedures and publicity, there is the possibility that it might not be the acceptable option if it is the intention of both parties to maintain a good status of relations in order not to damage the flow of business after the dispute. A considerably assertive legal action may convert a future business relationship unpleasant. The possibility of public degradation might coerce the loosing faction to strike back or at least even the score. The application of arbitration has a reduced amount of belligerence in its nature. The atmosphere and procedure in which this is executed augments the idea of peaceful dispute resolution.
Disadvantages of Traditional Commercial Arbitration
Aside from the advantages of traditional commercial arbitration, there also exist the downside of it. The arbitration clause is signed from the moment that the two opposing parties are raring to go on trade with each other. Regrettably, once the parties start to disagree, tend to argue on all possible points. Nevertheless, these discussions instead of acquiring hasty solutions turn delays. Moreover, arbitration hearings are not always carried out in the quick and effective manner in which they were intended. Delaying tactics might be taken as a tool; or otherwise one of the parties might have been intimidated into participating in the arbitration. These are aspects that by now have an effect on arbitration in the present day. While technology could alter the parties’ thoughts towards rewarding their contractual commitment to arbitrate it could expedite the interaction between the parties and the tribunal.
Moreover, the effectiveness of private international arbitration is dependent “on substantial and predictable governmental and intergovernmental support.”[25] This reality leads to the irrefutable logic that in the absence of “reciprocal commitments and effective control,” there is little reason to believe that one country’s courts would allow its citizens’ property to be confiscated simply because a private actor has ruled so. Taking this logic a step forward, without the assurance of enforcement by a national court in whose territory an award debtor’s property is located, international commercial arbitration simply will not work. (p.139) But it has worked.[26] Unlike criminal law, where ideological and other differences between nations have prevented the forming of a unified rule of international law,[27] in private, commercial matters, nations have been willing and able to reach some consensus.[28] Without such a consensus, the explosive expansion of international commerce and the recognition of the global economy would be in doubt.[29] The decision of an arbitrator, however, does not necessarily result in the resolution of a dispute. Parties to an arbitral proceeding will often resort to domestic proceedings in local courts to enforce either the agreement to arbitrate or the award decision reached by the arbitrator.[30] With the assigned roles of an arbitral tribunal and domestic courts, it is inevitable that contradictory rulings may occasionally occur. This inconsistency can be particularly problematic when a domestic court and an arbitral tribunal disagree in implementation of enforcement provisions of the United Nations Convention on the Recognition and Enforcement of Foreign `Arbitral Awards, also known as the “New York Arbitration Convention of 1958″ (Convention).
Definition of Online Arbitration
In this time and age, transactions are often take place through the World Wide Web. Commercial transactions conducted on this medium are labelled as e-commerce. Nevertheless, with the purpose for e-commerce to persist to flourish, legal confidence should subsist such that commercial transactions completed online will be put in force in the physical world. A dependable and enforceable dispute resolution mechanism customized exclusively to the needs of the e- commerce milieu would assist in the progress of such officially authorized certainty. Proposed solutions on online dispute includes online alternative dispute resolution (ADR) intuitions that assimilate either a mediation or arbitration model, or some sort of combination of the two.[31]
As noted earlier, the idea of taking legal action in a foreign jurisdiction under foreign rules is taken rather anxiously by all businesses engaged in international transactions, including those now partaking in online ventures. The best solution historically for the resolution of international commercial disagreements has been conventional ADR services. As stated earlier, ADR is normally speedy, efficient and confidential. Nevertheless, it is inappropriate for settling online commercial disputes, predominantly for the reason that legal revolution have insulated in the wake of the changes in the social, technological, and commercial mores of cyberspace. Moreover, creative entrepreneurs and academics have thus devised dispute resolution programs on the web.[32] The aptitude to play a part in an online proceeding of this category generates a freer market for dispute resolution, a market unfettered by anxiety of locality or time. The accessibility of online arbitration services enables parties at anyplace and at any time to commence or take action to a petition by accessing a website and finishing electronic forms that steer them through the numerous stages of the course of action. Moreover, the individual parties are able to become accustomed to the process particularly to their precise needs and utilize multimedia technology to conserve time and money. [33] This sleek and collectively obtainable process diminishes entry impediments to arbitration for businesses and individual parties, providing a new means of access to justice.
Why We Need Online Arbitration
In the World Wide Web, resolution of disputes are opposite of a number of essential disturbing troubles. Initially, the individual factions on the web more often wouldn’t have seen each other in the physical world considering they live actually in different nations or continents. In the real world, common consumers do habitually not go into an international agreement. On the other hand, in the Internet, they would have taken advantage of small transactions, which is unusually for them considering they would have second thoughts in acquiring assets in the physical world.[34] As stated earlier in this chapter courts normally are slow and expensive. Furthermore, courts are considered as a financially irrational channel to resolve disagreement arising from the World Wide Web. The factions to such small or medium-sized disagreements in the web will time and again have hardwearing economic enticement not to pursue court proceedings, leaving the fraudulent party with a victory.[35]
Additionally, online arbitration could provide this effectiveness, because the alternative to legal actions in courts is barely negligible and therefore much less costly. [36]Nevertheless, difficulties follow from this form of legal effectiveness. Online arbitration compels the factions to give up some of their liberties, which does not stimulate faith and which is the motive why arbitration at present still deal with a sequence of legal hindrances. In terms of the claims of the consumer, there is for instance a predicament of arbitrability beneath a quantity of regulations.[37] Though it is acceptable that most of these legal hindrances are simply errors in the legal system these obstacles are still there.
Advantages of online arbitration
The international market offered by e-commerce creates peril that may be taken in hand by incorporating arbitration clauses in online contracts. Introducing numerous customers one click far from carrying out a business deal that generates the risk of thousands of consumers putting on record lawsuits in their domestic locations or a fusion in a class action lawsuit.[38]
The process of arbitration occurs when a third party is chosen by the parties involved, or proposed by the institution selected by the factions, provides a decision on a case while applying fundamental procedural principles. Conventionally, similar to traditional arbitration, its online counterpart resolves a dispute by making a practical decision.[39] This is what is labelled as the binding form of arbitration. It is a procedure where judgments are enforceable by the powers that be. The philosophy of binding arbitration online is that it comprises a mode of private judging, a substitute for court litigation.
Thus, in the milieu commerce in the World Wide Web, arbitration’s supplementary remuneration of guaranteeing an adjacent medium for resolution of the dispute and eliminating the presence of class action lawsuit stand up to added importance.[40] Online arrangements may take account of an arbitration stipulation with a forum assortment clause and a preference of law clause.
Reference:
Berger, K.P. (1998) International Arbitral Practice and the UNIDROIT Principles of International Commercial Contracts, American Journal of Complementary Law Vol. 40. No. 129
Burger, W. E. (1982) Isn’t There a Better Way? American Business Association Journal Vol. 60, No. 274
Coe, J. Jr. (1997) International Commercial Arbitration: American Principles And Practice In A Global Context. Transnational Publishers Inc.
Craig, W., Park, W. and Paulsson, J. (1990) International Chamber of Commerce Arbitration, 2d ed. Oceana Publications, Dobbs Ferry, NY.
David, R. (1985) Arbitration in International Trade . Deventer, The Netherlands: Kluwer Law and Taxation Publishers.
Davidson, G. (1998) Jurisdiction Over Non-U.S. Defendants. In International Commercial Litigation, PLI Commercial Law Practice Course Handbook Series No. A4-4539
Katsh, E., Rifkin, J., Gaitenby, A., (2000) E-commerce, E-Disputes, and E-Dispute Resolution in the Shadow of eBay law, Ohio State Journal of Dispute Resolution, No. 15 , pp.705
Katsh, E., (2000) New frontier. Online ADR becoming a global priority, in Dispute Resolution Magazine, winter, pp..6.
Lalive, P., (1999) Towards a Decline of International Arbitration?, The Journal of the Chartered Insitute of Arbitrators, No. 4.
Lasprogata, G. (2001) Virtual Arbitration: Contract Law and Alternative dispute resolution, Journal of Legal Studies Education Vol. 19 No. 107
Lew, J. (1978) Applicable Law in International Commercial Arbitration: A Study in Commercial Arbitration Awards . Oceana Publications Dobbs Ferry, NY.
Lowenfeld, A. F. (1993) International Litigation And Arbitration. West Information Pub Group.
Redfern, A. and Hunter, M. (1991) Law and Practice of International Commercial Arbitration 2d ed. Sweet and Maxwell, London.
Reisman, W. (1992) Systems Of Control In International Adjudication And Arbitration. Durham, Carolina. Duke University Press.
Robert, J. (1967) Arbitrage: Civil et Commercial . Dalloz, Paris.
Robert, J. and Carbunneau, T. (1983) The French Law of Arbitration. Matthew Bender, New York..
Sauser-Hall, G. (1952) “L’Arbitrage en droit international Privé” Ann. Inst. Dr. Int’l Vol. 44-1
Smit, H. (1989) “A-National Arbitration” Tulane Law Review Vol. 629 No. 63
Steven A. Meyerowitz, The Arbitration Alternative, American Business Association Journal Vol. 71 No. 78.
Titigawa, K. (1967) “Contractual Autonomy in International Commercial Arbitration” in P. Sanders (ed.) International Arbitration: Liber Amicorum for Martin Domke. Martinus Nijhoff. Hague.
United Nations General Assembly Resolution 40/71, 40 GAOR Supp. No. 53, A/40/53 at 307.
Vahrenvald, A. (2000) Out of Court dispute settlement systems for e-commerce, Report on legal issues, Joint Research Centre of the EC, Ispra (Italy), 29th May
van den Berg, A. J. (1981) The New York Convention of 1958: Towards a Uniform Judicial Interpretation. Kluwer Law and Taxation Publishers, Deventer, The Netherlands.
van den Horen, H. (1984) “Commercial Disputes and Their Settlement: A Factor in Business Planning” in International Arbitration: 60 Years of ICC Arbitration–A Look at the Future . ICC Publishing, Paris.
Walton, A. and Victoria, M. (1982) Russell on Arbitration 20th ed. Stevens. London.
Wilner, G. M. (1996) Domke on Commercial Arbitration: the Law and Practice of Commercial Arbitration. Deerfield, IL
[1] David, R. (1985) Arbitration in International Trade . Deventer, The Netherlands: Kluwer Law and Taxation Publishers.
[2] van den Horen, H. (1984) “Commercial Disputes and Their Settlement: A Factor in Business Planning” in International Arbitration: 60 Years of ICC Arbitration–A Look at the Future . ICC Publishing, Paris.
[3] Robert, J. (1967) Arbitrage: Civil et Commercial . Dalloz, Paris.
[4] Redfern, A. and Hunter, M. (1991) Law and Practice of International Commercial Arbitration 2d ed. Sweet and Maxwell, London.
[5] Walton, A. and Victoria, M. (1982) Russell on Arbitration 20th ed. Stevens. London.
[6] Lew, J. (1978) Applicable Law in International Commercial Arbitration: A Study in Commercial Arbitration Awards . Oceana Publications Dobbs Ferry, NY.
[7] supra. Redfern and Hunter, 1991
[8] Titigawa, K. (1967) “Contractual Autonomy in International Commercial Arbitration” in P. Sanders (ed.) International Arbitration: Liber Amicorum for Martin Domke. Martinus Nijhoff. Hague.
[9] supra. Lew, 1978
[10] Sauser-Hall, G. (1952) “L’Arbitrage en droit international Privé” Ann. Inst. Dr. Int’l Vol. 44-1
[11] supra. Lew, 1978
[12] Robert, J. and Carbunneau, T. (1983) The French Law of Arbitration. Matthew Bender, New York..
[13] van den Berg, A. J. (1981) The New York Convention of 1958: Towards a Uniform Judicial Interpretation. Kluwer Law and Taxation Publishers, Deventer, The Netherlands.
[14] Craig, W., Park, W. and Paulsson, J. (1990) International Chamber of Commerce Arbitration, 2d ed. Oceana Publications, Dobbs Ferry, NY.
[15] Smit, H. (1989) “A-National Arbitration” Tulane Law Review Vol. 629 No. 63
[16] Coe, J. Jr. (1997) International Commercial Arbitration: American Principles And Practice In A Global Context. Transnational Publishers Inc.
[17] Lowenfeld, A. F. (1993) International Litigation And Arbitration. West Information Pub Group.
[18] Davidson, G. (1998) Jurisdiction Over Non-U.S. Defendants. In International Commercial Litigation, PLI Commercial Law Practice Course Handbook Series No. A4-4539
[19] supra. Lowenfeld, A. F. (1993)
[20] Meyerowitz, 1985
[21] Wilner, G. M. (1996) Domke on Commercial Arbitration: the Law and Practice of Commercial Arbitration. Deerfield, IL
[22] Burger, W. E. (1982) Isn’t There a Better Way? American Business Association Journal Vol. 60, No. 274
[23] Reisman, W. (1992) Systems Of Control In International Adjudication And Arbitration. Durham, Carolina. Duke University Press.
[24] Berger, K.P. (1998) International Arbitral Practice and the UNIDROIT Principles of International Commercial Contracts, American Journal of Complementary Law Vol. 40. No. 129
[25] supra. Reisman, 1992
[26] Ibid.
[27] Koh, 1987
[28] Carbonneau, 1989
[29] supra. (Lowenfeld, 1993)
[30] Bucher, 1994
[31] supra. Lasprogata, 2001
[32] supra. (Katsh, Rifkin, and Gaitenby, 2000
[33] supra. (Katsh, 2000)
[34] supra. Lalive, 1999
[35] supra. Varenvald, 2000
[36] supra. Lasprogata, 2001
[37] supra. Katsh, Rifkin, and Gaitenby, 2000
[38] supra. Lalive, 1999
[39] supra. Varenvald, 2000
[40] supra. Katsh, 2000
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