Juraeva, Asal., and Khumoyun Soyipov, “Chinese International Commercial
Courts: Overview and Potential Questions Around It.” Hasanuddin Law
Review 8 no. 1 (2022): 1-17. DOI: 10.20956/halrev.v8i1.3582

HasanuddinLawReview
Volume 8 Issue 1, April 2022
P-ISSN: 2442-9880, E-ISSN: 2442-9899
This work is licensed under a Creative Commons Attribution 4.0 International License

Chinese International Commercial Courts: Overview and
Potential Questions Around It
Asal Juraeva1, Khumoyun Soyipov2
1 Tashkent State University of Law, Uzbekistan. E-mail: asaljuraeva@stu.xjtu.edu.cn
2 Tashkent State University of Law, Uzbekistan. E-mail: kh.soyipov@tsul.uz

Abstract: People’s Republic of China (PRC) established China’s International Commercial Courts (CICC)
and became one of the global competitors that offers international commercial dispute settlement
service. Basically, the CICC formed to assist the enhancement of the “Belt and Road Initiative”. The
formation of the CICC was an important progress in the judicial system of the PRC. The Supreme People’s
Court (SPC) of the PRC equips the CICC with the necessary judicial interpretation. This article analyses the
establishment of the CICC and its significant features. The goal of this research is to illustrate a detailed
overview and thorough research regarding to the CICC. The current work also provides answers to the
potential misunderstandings around the CICC. Based on the existing works of distinguished scholars some
improvements regarding to CICC is incorporated in the research. The author also provides a
comprehensive analysis of the functioning and structure of the CICC.
Keywords: Belt and Road Initiative; China; International Commercial Court

1. Introduction
The international commercial courts have been prepotent means of international
business dispute settlement mechanism over the years. Many countries are gradually
establishing international commercial courts in the recent years. The establishment of
the China’s International Commercial Courts (hereinafter CICC) aimed to facilitate
China’s Belt and Road Initiative (hereinafter BRI). The authorities of the People’s
Republic of China (hereinafter PRC) promulgated two principal documents regarding to
the dispute resolution framework within BRI in June 2018. First was “Opinion
Concerning the Establishment of the Belt and Road International Commercial Dispute
Resolution Mechanism and Institutions”1 and the next one is “Provisions of the
Supreme People’s Court on Several Issues Regarding the Establishment of the
International Commercial Court”.2 The primary declaration of the both documents
envisaged the organization of the CICC as a dispute settlement structure for BRI.
Moreover, this endeavor also assisted to promote and consolidate international dispute

1 “Opinion Concerning the Establishment of the Belt and Road International Commercial Dispute Resolution
Mechanism and Institutions. 关于建立’一带一路’国际商事争端解决机制和机构的意见,” accessed September 15,
2020, http://cicc.court.gov.cn/html/1/219/208/210/819.html.
2 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” accessed September 14, 2020, https://cgc.law.stanford.edu/belt-and-road/b-and-rtexts/20180701-provisions-re-intl-commercial-courts/.

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settlement mechanism of the PRC. The CICC offers international dispute settlement
mechanism in a distinctive way compared to usual litigation practice of the PRC.
The formation of the CICC marked the pivotal stage in the headway of the BRI.
Moreover, the CICC reflected historical milestone of the leading policy of the PRC to
integrate international trade and broader foreign policy since 2013. 3 In addition, the
CICC can be viewed as a competent member of the following international commercial
courts’ family (Table 1).
Table 1. List of International Commercial Courts
Country
Great
Britain
Singapore
Germany
PRC
Netherlands
Qatar
UAE
UAE
France
Kazakhstan
Belgium

Court
ICC constituting the branch of the domestic judicial system 4
The English Commercial Court (ECC)5
Singapore International Commercial Court (SICC)6
Chamber for International Commercial Disputes at the Landgericht Frankfurt am
Main7
Chinese international commercial courts (CICC)
Netherlands Commercial Court (NCC)8
ICC connected to the special economic zones practicing common law 9
The Qatar International Court and Dispute Resolution Centre (“QICDRC”)10
Dubai International Financial Centre (DIFC)11
Abu Dhabi Global Market Courts (ADGM Courts)12
The International Chambers of the Paris Commercial Court and the Paris Court of
Appeal (Paris ICCs)13
Astana International Financial Centre (AIFC)14
An autonomous business court15
Brussels International Business Court (BIBC)16

Year of
Establishment
1895
2015
2018
2018
2019
2009
2014
2015
2010
2018
2018
2020

3 David Holloway, The New Chinese International Commercial Court and the Future of Dispute Resolution in the Belt
and Road Initiative, 2020.
4 Long Fei (龙飞), Deputy Director of the Office of Coordination and Leadership of the International Commercial
Arbitration Court of the 4th Civil Division of the Supreme People’s Court, Lecture on Rule of Law in Eurasia under the
Belt and Road Initiative program “Specifics and experience of the International Commercial Court of the PRC” on 21
September 2020.
5 Sheng Zhang, “China’s International Commercial Court: Background, Obstacles and the Road Ahead,” Journal of
International Dispute Settlement 11, no. 1 (2020): 150–74, https://doi.org/10.1093/jnlids/idz029.
6
“Report
of
the
Singapore
International
Commercial
Court
Committee,”
2013,
https://www.sicc.gov.sg/docs/default-source/modules-document/news-and-article/-report-of-the-singaporeinternational-commercial-court-committee-_90a41701-a5fc-4a2e-82db-cc33db8b6603-1.pdf.
7 Burkhard Hess and Timon Boerner, “Chambers for International Commercial Disputes in Germany: The State of
Affairs,” Erasmus Law Review 12, no. 1 (2020): 33–41, https://doi.org/10.5553/elr.000121.
8 Jeroen A. van der Weide, “The Netherlands Commercial Court (NCC): Its Challenges and Perspectives” (Springer,
Cham, 2020), 81–108, https://doi.org/10.1007/978-3-030-42974-4_4.
9 Long Fei (龙飞).
10 Anselmo Reyes and Kevin Tan, Recognition and Enforcement of International Commercial Court Judgments, 2020.
11 Stephen Thomas, Kamaldeep Panesar, and Christina Makris, “Dubai as an International Financial Centre Threats
and Opportunities ,” 2013, www.cassknowledge.com/cass-consulting.
12 Anselmo Reyes and Kevin Tan, Recognition and Enforcement of International Commercial Court Judgments, 2020.
13 Anselmo Reyes and Kevin Tan.
14 “The Astana International Financial Centre: AIFC Court and International Arbitration Centre Legal Systems to Be
Based on English Common Law,” accessed September 24, 2020, http://arbitrationblog.kluwerarbitration.com/
2017/08/06/astana-international-financial-centre-aifc-court-international-arbitration-centre-legal-systems-basedenglish-common-law/.
15 At the time of writing this research work the Brussels International Business Court (BIBC) has not been
established.
16 Erik Peetermans and Philippe Lambrecht, “The Brussels International Business Court: Initial Overview and
Analysis,” Erasmus Law Review 12, no. 1 (2019): 42–55, https://doi.org/10.5553/elr.000117.

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Hasanuddin Law Rev. 8(1): 1-17

Initially, the current research article examines background of the BRI and followed
by the construction of the CICC. Next, depicts the CICC’s unique characteristics,
unsolved questions and common misunderstandings around the CICC. Finally, in
accordance with the existing research works, the author concludes by presenting own
comments on the perspectives and some concerns regarding to the CICC.

2. Background of the BRI and its finance
In Kazakhstan (2013) the PRC President Xi Jinping declared the establishment of the BRI.
The BRI intends to enhance trade and economic cooperation in a greater level by
revitalizing historic network of the Silk Road. The initiative promotes to expand
economic partnership, boost long-term trade and investment cooperation.17 The
government of the PRC announced the BRI is open to all countries and organizations
across the globe. At the commencement of the BRI, it has 64 member-economies while
it is scope largely expanding.18
Table 2. List of BRI-Participating Economies19
Region

Economy

East Asia

People’s Republic of China, Mongolia

Southeast Asia
South Asia

Brunei, Cambodia, Indonesia, Lao People’s Democratic Republic, Malaysia,
Myanmar, Philippines, Singapore, Thailand, Timor-Leste, Viet Nam
Afghanistan, Bangladesh, Bhutan, India, Maldives, Nepal, Pakistan, Sri Lanka

Central Asia

Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, Uzbekistan

Middle East and
North Africa
Europe and Central
Asia

Bahrain, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi
Arabia, Palestinian Authority, Syria, United Arab Emirates, Yemen
Albania, Armenia, Azerbaijan, Belarus, Bosnia and Herzegovina, Bulgaria,
Croatia, Czech Republic, Estonia, Georgia, Hungary, Latvia, Lithuania, Former
Yugoslav Republic of Macedonia, Moldova, Montenegro, Poland, Romania,
Russian Federation, Serbia, Slovakia, Slovenia, Turkey, Ukraine
Ethiopia, Kenya, Morocco, New Zealand, Panama, Korea, South Africa

21st Century Maritime
Silk Road

The BRI has two main divisions: Silk Road Economic Belt for the land routes and 21st
Century Maritime Silk Road for the marine routes. The BRI includes three routes in
land:20
▪ 1-route. Links PRC and Europe via Russia and Central Asia;
▪ 2-route. Connects PRC and the Middle East via Central Asia;
▪ 3-route. Connects PRC, South East Asia and the Indian Ocean.

17 Holloway, The New Chinese International Commercial Court and the Future of Dispute Resolution in the Belt and
Road Initiative.
18 “China’s Belt and Road Initiative in the Global Trade, Investment and Finance Landscape,” OECD Business and
Finance Outlook, 2018, 61–101, https://doi.org/10.1787/bus_fin_out-2018-6-en.
19 “China’s Belt and Road Initiative in the Global Trade, Investment and Finance Landscape.”; China International
Trade Institute.
20 Holloway, The New Chinese International Commercial Court and the Future of Dispute Resolution in the Belt and
Road Initiative.

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21st Century Maritime Silk Road consists two routes: 1-route. Links PRC and Europe via
the South China Sea and the Indian Ocean; 2-route. Connects PRC and the South Pacific
Ocean via the South China Sea.
Within BRI six economic corridors established along above counted routes. These
economic corridors reflect the essential factors of the PRC development paradigm. The
economic corridors of the BRI cover a massive territory that is rich in resources and
energy. Six economic corridors can be viewed in the following map. Moreover, on
Appendix I one can see the whole picture of the BRI involved economies and respective
economic corridors.
Figure 1. Map of BRI’s six economic corridors21

The initiation of the Asian International Investment Bank (hereinafter AIIB) was
promulgated in October 2013 during the visit of the PRC President Xi Jinping to
Indonesia. The AIIB started its functioning in January 2016 and it has more than 82
affirmed member countries.22 The bank provides funds for infrastructure projects that
targeting to advance economic relations and regional connectivity. Moreover, it also
envisages to increase social and economic output in whole Asia and worldwide. The AIIB
has the cooperation with private financial institutions, banks and other organizations
both public and private. The bank provides sponsorship for variety of projects. 23

21 Angaindrankumar Gnanasagaran, “Dealing with the Belt Road Initiative ,” The ASEAN Post, accessed September
26, 2020, https://theaseanpost.com/article/dealing-belt-road-initiative.
22 “Members and Prospective Members of the Bank of the AIIB,” accessed September 26, 2020,
https://www.aiib.org/en/about-aiib/governance/members-of-bank/index.html.
23 AIIB offers sovereign and non financing for sound and sustainable projects in energy and power, transportation
and telecommunications, rural infrastructure and agriculture development, water supply and sanitation,
environmental protection, and urban development and logistics. accessed September 26, 2020,
https://www.aiib.org/en/about-aiib/who-we-are/our-work/index.html.

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According to the latest statistics, the AIIB funded more than 95 approved projects24
worth around 20.37 billion USD.25 On 29 December 2014 the government of the PRC
launched 40 billion USD Silk Road Fund in order to finance economic cooperation and
trade within BRI. The Silk and Road Fund intends to invest medium and long-term
financing via different systems i.e., investment in funds/debt or equity investment.26 It is
anticipated that the total amount of the net investment in the region included in BRI
projects is approximately one trillion USD.27 (On Appendix II one can see broader picture
of the finance of the BRI)

3. Formation of International Commercial Courts
Since the promulgation of the BRI, the government of the PRC has been investing a
great deal of international trade agreements and other projects between companies
and BRI states.28 In fact, with the rapid growth of the economic globalization and
cooperation, the international commercial disputes began occurring relatively more.
According to the reported data, in total above 200,000 international civil and
commercial disputes were recorded between 2013 and 2017 in all levels of the People’s
Courts of the PRC. This is two folds more than the last five years in the history of the
judicial system of the PRC.29 Therefore, the PRC has an opportunity to become an
essential center of the international dispute settlement system within investment and
trade related disputes of the BRI.30 The SPC designed and constructed the CICC in order
to facilitate the BRI with efficient, neutral, convenient, internationalized and fair dispute
resolution system.31 The establishment of the CICC conforms with the universal
tendency of the existing international financial centers and commercial court. 32
The notion of the CICC was primary announced to public according to the Opinion
regarding Establishing One Belt One Road International Commercial Dispute Resolution
Mechanism and Institution (Opinion) in January 2018.33 The Opinion envisaged that the
SPC will initiate the followings:
a. The international commercial court;
b. An expert committee of international commercial matters;
c. A “one-stop” dispute resolution center.
24 “AIIB Approved Projects,” Status as at September 24, 2020, accessed September 26, 2020,
https://www.aiib.org/en/projects/list/index.html?status=Approved.
25 “AIIB Approved Financing Projects,” para. Status as at September 24, 2020, accessed September 26, 2020,
https://www.aiib.org/en/projects/summary/index.html.
26 Holloway, The New Chinese International Commercial Court and the Future of Dispute Resolution in the Belt and
Road Initiative.
27 Joshua Kelly and Mariia Puchyna, “Investment Protection and Dispute Resolution on the Belt and Road ,”
accessed September 26, 2020, https://riskandcompliance.freshfields.com/post/102f1it/investment-protection-anddispute-resolution-on-the-belt-and-road.
28 Lu Yanan, “China’s Merchandise Trade with Belt and Road Countries Tops $5 Trillion in 5 Years,” 2018, para.
China has signed 118 cooperation agreements with 103 countries and international organizations on developing the
Belt and Road, http://en.people.cn/n3/2018/0831/c90000-9496013.html.
29
Liu
Tingmei,
“The
China
International
Commercial Court
(CICC)
in
2018,”
2019,
http://cicc.court.gov.cn/html/1/219/208/209/1316.html.
30 Jingzhou Tao and Mariana Zhong, “The China International Commercial Court (CICC): A New Chapter for
Resolving International Commercial Disputes in China,” The Journal of the Dispute Resolution Section of the
International Bar Association, no. Vol 13 No 2 (2019): 103–196.
31 “国际商事法庭 - Procedural Rules for the China International Commercial Court of the Supreme People’s Court
(For Trial Implementation).”
32 Such as Astana International Financial Centre Court, Dubai International Financial Centre Courts, Singapore
International Commercial Court and so on.
33 “Opinion Concerning the Establishment of the Belt And Road International Commercial Dispute Resolution
Mechanism and Institutions. 关于建立’一带一路’国际商事争端解决机制和机构的意见.”

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The Opinion defined the formation of the CICC. In June 2018, the SPC issued Provisions
of the Supreme People’s Court on Several Issues Regarding the Establishment of the
International Commercial Court as guidelines of the Opinion (CICC Provisions). 34 The
CICC Provisions provide articles on CICC jurisdiction, choice of law, selection of judges,
rules of evidence, language, the establishment of the international commercial expert
committee, a “one-stop” dispute resolution center and other related formalities.35 Soon
after promulgation of the CICC Provisions, on 5th December 2018 the SPC circulated
three Ancillary Rules that elucidates undetermined matters of the CICC Provisions and
assists to its implementation. The Ancillary Rules are the followings:
1. Notice of the General Office of the Supreme People’s Court on the Determination
of the First Batch of International Commercial Arbitration and Mediation
Institutions Incorporated into the ‘One-stop’ International Commercial Dispute
Diversified Resolution Mechanism (the ‘One-stop Solution Notice’);36
2. Procedural Rules of the China International Commercial Court of the Supreme
People’s Court (Trial) (the ‘Procedural Rules of CICC’); 37
3. Working Rules of the International Commercial Expert Committee (hereinafter
ICEC) of the Supreme People’s Court (Trial) (the ‘Working Rules of ICEC’). 38
On 29th June 2018 the SPC announces the establishment of the first and second
International Commercial Courts in Shenzhen and Xi’an, respectively. The first batch of
eight judges of the CICC has been appointed by the SPC. 39 All those judges served in the
SPC and specialized in dealing with international commercial disputes.40 On 24 August
2018, the SPC unveiled the formation of an ICEC that includes Chinese and foreign
specialists expertized in international investment and commercial arbitration,
international trade, construction and so on.41

4. Characteristic Features of the CICC
The current section discusses the characteristic features of the CICC mechanism.
The CICC constitutes the permanent adjudicatory body of the SPC.42 The SPC appointed
15 judges by April 2019, who has in-depth knowledge and expertise in trial work,

34 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts.”
35 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” accessed September 16, 2020, https://cgc.law.stanford.edu/belt-and-road/b-and-rtexts/20180701-provisions-re-intl-commercial-courts/.
36 “Notice of the Supreme People’s Court on Inclusion of the First Group of International Commercial Arbitration
and Mediation Institutions in the ‘One-Stop’ Diversified International Commercial Dispute Resolution Mechanism,”
accessed September 17, 2020, http://cicc.court.gov.cn/html/1/219/208/210/1144.html.
37 “Procedural Rules for the China International Commercial Court of the Supreme People’s Court (For Trial
Implementation),” accessed September 17, 2020, http://cicc.court.gov.cn/html/1/219/208/210/1183.html.
38 “Working Rules of the International Commercial Expert Committee of the Supreme People’s Court (For Trial
Implementation),” accessed September 17, 2020, http://cicc.court.gov.cn/html/1/219/208/210/1146.html.
39 “Eight Judges of China International Commercial Court Were Appointed,” accessed September 17, 2020,
http://cicc.court.gov.cn/html/1/219/208/210/821.html.
40 Jingzhou Tao and Mariana Zhong, “The China International Commercial Court (CICC): A New Chapter for
Resolving International Commercial Disputes in China.”
41 “Decision of the Supreme People’s Court on the Appointment of the First Batch of Expert Members of the
International Commercial Expert Committee - 最高人民法院关于聘任国际商事专家委员会首批专家委员的决定,”
accessed September 17, 2020, http://cicc.court.gov.cn/html/1/218/149/192/949.html.
42 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 1.

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proficient in working languages, acquainted with international treaties and practices. 43
According to the Law on Judges of the PRC, Chinese judges must have the nationality of
the PRC.44 As it is said above the CICC is the branch of the SPC which means Law on
Judges of the PRC applies to it. Therefore, the unique feature of the CICC is that all its
judges have Chinese nationality while other international commercial courts worldwide
welcome foreign judges as well.
The next particular feature of the CICC is the expert committee (ICEC) which comprised
leading practitioners from PRC and various jurisdictions. The ICEC is professional,
international, inclusive and universal. The ICEC experts preside over mediation; provide
advisory opinion on particular legal issues regarding to international treaties, laws,
regulations; assist in the formulation of the judicial interpretation and judicial policy of
the SPC and they also provide their valuable suggestion on the further development of
the CICC. The ICEC provides advice on various legal issues. Besides, as the ICEC experts
can act only as mediators, they cannot decide a case as a judge.45
The disputes in the CICC are handled by a collegial panel with three or more judges. The
novelty here is the collegiate panel follows the decision of the majority and the opinions
of the minority may be provided in the judgment.46 Moreover, the CICC hears the cases
as the first instance and its judgments is final, does not subject to appeal. However,
pursuant to Article 16 of the CICC Provisions, the parties of a dispute can apply the SPC
for retrial over the judgment, ruling or mediation statement. Furthermore, the CICC has
some lucid requirements for the admissibility of evidence obtained outside the territory
of the mainland of the PRC. The evidences are cross-examined in court regardless
weather they were notarized, certified or went through other formalities of
certification.47 More interestingly, the CICC can utilize audiovisual transmission
technology for investigation and cross-examination.48 Unlike PRC’s current litigation
system, the CICC allow to submit documents in English without Chinese translation,
with the consent of the other party.49 Besides the CICC has preservation ruling that
helps to designate a lower-level People’s Court to enforce its ruling. 50
The CICC Provisions do not provide rules for the enforcement of the judgments issued
by foreign courts or enforce CICC judgments in foreign jurisdiction. Thus, the
enforcement and recognition matters are governed only by Chinese Civil Procedure
Law (hereinafter CCPL) and bilateral treaties on judicial assistance.51 This aspect can
43 Wei Cai and Andrew Godwin, “Challenges and Opportunities for the China International Commercial Court,”
International and Comparative Law Quarterly 68, no. 4 (2019): 869–902, https://doi.org/10.1017/
S0020589319000332.
44 “中华人民共和国法官法 (2019年）Judges Law of the P.R.C.,” Article 12, accessed September 19, 2020,
https://www.chinalawtranslate.com/en/judges-law-of-the-prc-2019/.
45 Cai and Godwin, “Challenges and Opportunities for the China International Commercial Court.”
46 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 5.
47 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 9.
48 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 10.
49 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 9 (2).
50 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 6.
51 “Civil Procedure Law of the PRC,” 1991, https://www.wipo.int/edocs/lexdocs/laws/en/cn/cn012en.pdf; Cai and
Godwin, “Challenges and Opportunities for the China International Commercial Court.”

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pose significant problems to enforce the CICC judgment, especially compared to
arbitration. Because the arbitral awards have better mechanism of enforcement
due to New York Convention. 52
Remarkably, in the CICC electronic litigation service platforms and several other
platforms are created. As the result numerous tasks i.e., registration of cases,
payment of fees, review of files, exchange of evidence, service of process, initiation of
courtroom proceedings, etc., can be accomplished through electronic data
network.53 More interestingly, the CICC provides the diversified international dispute
resolution system. An innovative approach of the CICC is that SPC chooses high
professionalized international commercial arbitration and mediation institutions that
can create platform to merge arbitration, mediation with litigation. Which forms the
one-stop dispute settlement hub. Afterwards, they cooperatively inaugurate a dispute
resolution platform with the CICC.54 This practice definitely provides considerable
convenience to the parties of a case.

5. Jurisdiction of the CICC
The CICC has jurisdiction over international commercial disputes. Other types of
disputes are excluded from the scope of the CICC such as the investor-state or state to
state disputes. According to the Article 8 of the Rules of Procedure of the CICC, the
parties’ consent to the jurisdiction of the CICC of the SPC, First or Second International
Commercial Court, must be in written form.55 Pursuant to the Article 2 of the CICC
Provisions, the CICC has jurisdiction over following cases:
1) Pursuant to Article 34 of the CCPL when the parties of a dispute selected that
the SPC has jurisdiction as a first-instance and the subject of a dispute amounted
no less than 300 million RMB;
2) When a Higher People’s Court has jurisdiction as a first-instance and considers
that the SPC needs to adjudicate the case;
3) Cases of first-instance that poses a “significant impact” on the PRC;
4) In accordance with the Article 14 of the CICC Provisions, the cases that involves
arbitration related preservation procedures i.e., enforcement or setting-aside of
an international arbitral award;
5) Other cases that the SPC believes the CICC has jurisdiction over them.
The jurisdiction of the CICC incorporates the statutory jurisdiction (see above items 2
and 5) and consensual jurisdiction (above item 1). The scope of Article 2 of the CICC
Provisions expands the SPC jurisdiction through CICC. Before pursuant to Article 21 of
the CCPL56, as a first instance the SPC had jurisdiction over the cases that has substantial
impact on entire country and cases that should be tried by the SPC. Moreover, formerly
the foreign related cases amounted above 300 million RMB could be submitted to a
52 Convention on the Recognition and Enforcement of Foreign Arbitral Awards. New York Convention, 1958.
53 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International

Commercial Courts,” Article 18.
54 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 11.
55 “国际商事法庭 - Procedural Rules for the China International Commercial Court of the Supreme People’s Court
(For Trial Implementation).”
56 “Civil Procedure Law of the PRC,” Article 21.

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Higher People’s Court only.57 Besides past constraint under the CCPL that the cases
regarding to arbitration could be filed to an Intermediate People’s Court, is now
removed.58 Additionally, the Article 3 of the CICC Provisions defined what actually
comprises “international commercial case”. The term “international” and “foreignrelated” resembles to each other.59 According to it the followings are determined as
“international” commercial cases:
a. the parties or one of the parties (person or legal entity) has a foreign nationality
or stateless status;
b. permanent residence of the parties or one of the parties is outside the territory
of the PRC;
c. a subject matter of the case located outside the territory of the PRC;
d. the legal facts triggered the dispute are outside the territory of the PRC.60
Pursuant to the Article 2 (1) of the CICC Provisions, the parties of a dispute can select
CICC as a dispute settlement forum, if the dispute has actual connection with PRC and
amount of the dispute is no less than 300 million RMB. Remarkably, this provision
confines the parties’ right for consensual jurisdiction. Primarily, drafting a constructive
dispute resolution clause by addressing CICC would pose a perplexity. This is mainly
because a party cannot estimate the amount of a dispute while drafting an agreement.
The relation between overall amount of a contract and the value of the dispute arising
within the contract is not always predictable.61
Moreover, Article 2 of the CICC Provisions allows the SPC to transfer some cases from
other courts to the CICC where even the total amount of a dispute is less than 300
million RMB. Interestingly, in this regard the party autonomy remains entirely in
question. The quantifiable limit can cause practical problems to the parties. 62
Furthermore, in order to select the CICC as a dispute settlement forum, a dispute
should have an actual connection with PRC. According to the Article 34 of the CCPL, a
consensual venue should have an actual connection with the forum. 63 For this reason
the CICC can fail to constitute a neutral dispute settlement venue for the BRI disputes.
In essence, the other types of jurisdiction in the Article 2 of the CICC Provisions can be
viewed as an inner designation of jurisdiction within PRC judicial system. Obviously, by
imposing limitation on consensual jurisdiction, the CICC can only handle the disputes
which are normally under PRC court’s jurisdiction. 64 Additionally, unlike CICC other
international commercial courts i.e., Singapore International Commercial Court (SICC) or

57 Jingzhou Tao and Mariana Zhong, “The China International Commercial Court (CICC): A New Chapter for
Resolving International Commercial Disputes in China.”
58 Jingzhou Tao and Mariana Zhong.
59 Article 522 of the SPC’s Interpretation of the Civil Procedural Law. See. Jingzhou Tao and Mariana Zhong.
60 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts,” Article 3.
61 Li Huanzhi, “China’s International Commercial Court: A Strong Competitor to Arbitration?,” 2018, accessed
September 23, 2020, http://arbitrationblog.kluwerarbitration.com/2018/09/30/chinas-international-commercialcourt-a-strong-competitor-to-arbitration/.
62 Wei Sun, “International Commercial Court in China: Innovations, Misunderstandings and Clarifications,” 2018,
accessed September 23, 2020, http://arbitrationblog.kluwerarbitration.com/2018/07/04/international-commercialcourt-china-innovations-misunderstandings-clarifications/.
63 “Civil Procedure Law of the PRC,” para. Article 34.
64 Huanzhi, “China’s International Commercial Court: A Strong Competitor to Arbitration?”

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Dubai International Financial Centre Courts (DIFCC) requires a jurisdiction agreement in
written form without having any actual connection with the forum.65

6. Procedure of the CICC
The CICC shares the virtually identical procedural rules with People’s Courts in PRC.
There are no specific rules on recognition, enforcement or choice of law. However, the
Procedural rules of the CICC have particular features. The following paragraph discusses
the unique characteristics of the CICC litigation procedures.
The CICC created flexible system of ascertaining foreign law. Article 8 of the CICC
Provisions enlarges the methods of ascertaining foreign law in the PRC. Previously,
“Opinions of the Supreme People’s Court on Several Issues concerning the
Implementation of the General Principles of the Civil Law of the People’s Republic of
China (For Trial Implementation)”66 (1988) defined five approaches of establishing
foreign law (Article 193).
The CICC facilitated convenience and flexibility for the parties. According to the Article 9
(2) of the CICC Provisions a party can submit evidentiary materials in English language,
without Chinese translation, but only if the other party agrees to do so. Regardless
whether the evidentiary materials generated outside the territory of the PRC are
notarized, certified or undergone other process of certification, they are be accepted
and cross examined in court. Moreover, Article 10 of the CICC Provisions utilizes stateof-the-art innovative audiovisual technology and other Internet related virtual methods
in order to conduct investigation, compile evidence and arrange cross-examination.
The electronic litigation platform is organized within the CICC practice. It reflected in
the Article 18 of the CICC Provisions, it defines that the parties can be informed about
trial process through platforms and they facilitate to pay fees, to get acquainted with
case documents, evidence exchange, service of process, trial by video-conference via
Internet connection. Besides, the Article 5 of the CICC provides innovative approach of
judgment. Which determines the minority opinions in the collegial panel can be
incorporated in the judgment.
The first public hearing of the dispute related to the product liability held in the First
International Commercial Court situated in Shenzhen on 31 st May 201967. The first case
associated with shareholder qualification confirmation in the Second International
Commercial Court located in Xi’an held on 29th June 2019.68 According to the statistics
by June 2019, the International Commercial Courts in Shenzhen and Xi’an accepted 11

65 Huanzhi.
66 “Notice of the Supreme People’s Court on Issuing the ‘Opinions on Several Issues Concerning the Implementation

of the “General Principles of the Civil Law of the People’s Republic of China” (for Trial Implementation),’” accessed
September 20, 2020, http://pkulaw.cn/fulltext_form.aspx?Gid=3689&Db=chl.
67 “The Dispute between Guangdong Bencao Medicine Group Co., Ltd. and Bruschettini S.R.L. over Product
Liability,” accessed September 21, 2020, http://cicc.court.gov.cn/html/1/219/208/210/1245.html.
68 “The Dispute of Shareholder Qualification Confirmation between Ruoychai International Group Co., Ltd., Red Bull
Vitamin Drink Co., Ltd. and Inter-Biopharm Holding Limited,” accessed September 21, 2020,
http://cicc.court.gov.cn/html/1/219/208/210/1231.html.

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different cases from various jurisdictions i.e., Japan, Hong Kong SAR of the PRC, Virgin
Islands, Italy and so on.69
Figure 2. The description of the CICC litigation procedure70

7. Analysis of Common Misunderstandings
As it has been already discussed above the CICC is the permanent division of the SPC.
The CICC has jurisdiction over international commercial cases among equal parties. The
following paragraph evaluates the potential questions that are not clearly determined.
The prominent internationalized commercial courts made the involvement of respected
foreign judges and expert lawyers indispensable. Nevertheless, Article 9 of the PRC
Judges Law requires judges of the PRC to have a Chinese nationality and prevents
foreign judges being accepted to CICC as a judge.71 Moreover, pursuant to the CCPL,
only Chinese-admitted lawyers can represent a party in litigation while limits the
participation of foreign lawyers.72
The CICC maintained an innovative approach by creating the ICEC as a mediator. Which
is in turn inexplicably withdraw the mediation function of the judicial panel. In addition,
the CCPL does not include any prerequisite for evidence disclosure prior to
commencement of the hearing. Thus, lawyers, especially from common law jurisdiction,
can be concerned about encountering surprising evidences during the trial. Hence, they
are more reluctant in determining PRC courts as a dispute resolution forum and opt for
the venue which grants more party autonomy.73
The CICC Provisions does not make it clear how to define the relation between
arbitration and litigation or among domestic/foreign courts and arbitration institution. 74
For example, when there is a contract between French company and Chinese company
69 “Review: The First Anniversary of China International Commercial Courts ,” accessed September 21, 2020,
https://www.chinajusticeobserver.com/a/review-the-first-anniversary-of-china-international-commercial-courts.
70 Cai and Godwin, “Challenges and Opportunities for the China International Commercial Court.”
71 “Judges Law of the People’s Republic of China,” Revue Internationale de Droit Comparé 55, no. 1 (2003): 75–82.
72 Huanzhi, “China’s International Commercial Court: A Strong Competitor to Arbitration?”
73 Huanzhi.
74 Sun, “International Commercial Court in China: Innovations, Misunderstandings and Clarifications.”

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worth 2 billion RMB, the parties decided to select CICC in Xi’an as a dispute settlement
forum. When a dispute arose, it amounted only 180 million RMB. The question here is
“Does the CICC in Xi’an still have jurisdiction?” Or what happens when the defendant
made a counter-claim and the same dispute amounted 500 million RMB?
A common misunderstanding around CICC is whether foreign international arbitral and
mediation institutions can be involved in “one-stop” dispute settlement system? The
Article 11 of the CICC Provisions provides that the CICC establishes “one-stop” dispute
settlement mechanism by linking qualified international mediation, arbitration
institutions and litigation in a one platform. The answer here is only Chinese institutions
with international practice (like CIETAC, BAC, SIAC, SCIA and etc.)75 can be involved in
this platform for now. Some of the considerable barriers should be removed prior to
foreign international institutions actually get included into this platform. 76
Pursuant to Article 14 of the CICC Provisions, the parties of arbitral proceedings can
apply for interim measures to CICC.77 The misconception here is that even the parties
are involved to foreign arbitral proceedings outside of PRC can apply for interim
measures to CICC. However, Article 14 of the CICC Provisions refers to the Article 11 of
the Provisions and defines only the parties of the arbitration proceedings within CICC
Platform can apply for interim measures to CICC. Which means the parties pursuing
arbitration proceedings abroad cannot apply to CICC for interim measures, even the
case involves a Chinese party.78
Another misinterpretation is that the procedural language can be English or even other
foreign language as the CICC established to assist disputes related to BRI. This mistake
occurs because the Article 4 of the CICC Provisions provides that the judges have
proficiency in working languages, both Chinese and English. Moreover, the Article 9 of
the CICC Provisions defines that the parties can submit their evidences in English
language without translating to Chinese language.79 In fact, the CICC Provisions do not
mention that the proceedings can be conducted in English. According to the Article 240
of the CCPL the court proceedings only can be held in “commonly used language in the
PRC” (Chinese language).80 Besides, Law on Court Organization of the PRC in Article 6
provides the same provisions.81 Thus, pursuant to current legislation framework of the
PRC, it is impossible to held court proceedings in foreign language in the PRC. 82 The PRC
laws have superior power compared to CICC Provisions and SPC judicial interpretations.

75 China International Economic and Trade Arbitration Commission (CIETAC); Beijing Arbitration Commission (BAC);
Shanghai International Economic and Trade Arbitration Commission (SIAC); Shenzhen Court of International
Arbitration (SCIA).
76 Sun, “International Commercial Court in China: Innovations, Misunderstandings and Clarifications.”
77 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts.”
78 Sun, “International Commercial Court in China: Innovations, Misunderstandings and Clarifications.”
79 “Provisions of the Supreme People’s Court on Several Issues Concerning the Establishment of the International
Commercial Courts.”
80 “Civil Procedure Law of the PRC.”
81 Sun, “International Commercial Court in China: Innovations, Misunderstandings and Clarifications.”
82 Sun.

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8. Conclusion
The development of the international commercial courts is linked to the need of the
fast and effective resolution of international commercial disputes. Despite the
arbitration plays an important role in international commercial dispute resolution, the
international commercial courts are filling its drawbacks and offering larger degree of
fairness. Both dispute settlement mechanisms complemental to each other. 83 The
growth of international commercial courts eventually confers to the further
development of the global commerce. It is anticipated that the jurisprudence designed
by professional judges and outstanding experts will definitely become an indispensable
asset of the lex mercatoria.84
Undoubtedly, the CICC will fully achieve its contemplated goals. It might seem unluckily
that the CICC will become prominent choice of forum in the international business
network. Basically, because of the problems regarding to the enforcement of the CICC
final judgement in foreign countries Therefore, the CICC is required to create a
necessary framework in order to facilitate enforcement mechanism for its judgments. In
fact, one of the advantages of the CICC is that the caseload will not be a problem. The
CICC ascertains which of the arbitral institutions will be incorporated in the one-stop
platform. Moreover, the preservative measures of the CICC attracts more arbitrationrelated disputes.
The establishment of the CICC was the important breakthrough in stimulating PRC’s
participation in the world business law-making, further integrate PRC’s international
organization of judicial cooperation, enforcement and recognition. This matches the
PRC’s intention to gain more significant position in international business rule
making process.85 The construction of the CICC marked as opening the door for a
new era in the PRC’s judicial system. Moreover, it demonstrated the PRC’s
influential vision towards rule of law. 86 Even though the PRC has influential
international arbitration institutions, it limits the growth of the PRC’s ability to
contribute to the progress of substantive commercial law. 87 It is mainly because
arbitral centers have ad hoc character and confidentiality requirements. The CICC
formed a fundamental framework for its functioning. If the CICC will promote more
internationalization, transparency and professionalism, it will become one of the
leading competitors across the globe in international dispute resolution service. 88
Even though the CICC has some shortcomings as discussed in the research, but
ultimately it can promote to the further development of the international rule of law
and judicial cooperation.

83 Zhang, “China’s International Commercial Court: Background, Obstacles and the Road Ahead.”
84 Sheng Zhang (2020).
85 See the Supreme People’s Court’s Several Opinions on Providing Judicial Service and Guarantee

for the
Construction of the ‘Belt and Road’ Initiative by People’s Court (最高人民法院关于人民法院为 ‘一带一路’
建设提供司法 服务和保障的若干意见) Issued on 16 June 2015., accessed September 21, 2020,
https://www.pkulaw.com/en_law/96f2607d78e93212bdfb.html.
86 Jiangyu Wang, “China’s Governance Approach to the Belt and Road Initiative (BRI): Relations, Partnership, and
Law,” Global Trade and Customs Journal 14, no. 5 (2019): 222–28.
87 Firew Tiba, “The Emergence of Hybrid International Commercial Courts and the Future of Cross Border
Commercial Dispute Resolution in Asia,” Loyola University Chicago International Law Review 14, no. 1 (2016).
88 Cai and Godwin, “Challenges and Opportunities for the China International Commercial Court.”

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Acknowledgement
We are very thankful to Prof. Wang Chaoen whose supervision and guidance played a
key role in the completion of this research in a timely manner while maintaining a high
standard. He has been very kind and helpful in every regard. Due to his deep hard work
and efforts during Chinese civil procedural law course, at the end of this course we have
full conceptual understanding related to Chinese civil procedural law. Also thankful to
all teachers of Xi’an Jiaotong University who provided us a great opportunity to learn
deep knowledge about different aspects of law field. Special thanks to the Ministry of
Innovation of the Republic of Uzbekistan for providing us with the free proof-reading
service of the “Springer nature”.

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