Admissibility in International Arbitration: Chimera or Chameleon (or not)?

The decisions of recent English and Hong Kong cases appear to hold essentially that a party’s failure to comply with certain pre-conditions contained in a multi-tiered dispute resolution clause is a question of admissibility of the claim and not of the tribunal’s jurisdiction over the claim. Michael Hwang thinks the position is more nuanced, as set out in his article “The Chimera of Admissibility in International Arbitration”.