Whatever the particular merits of specific proposals, the recent rash of guidelines and standards for best practices in arbitration suggests a robust concern for the contours of an arbitrator's duties. Among the principal duties, the first aims at rendering an accurate award, faithful to the text and the context of the relevant bargain. A second duty turns on respect for procedural fairness, a capacious concept that incorporates responsibility to hear before deciding, an obligation to respect the limits of arbitral authority, and a keen concern for impartiality and independence. The third obligation lies in an aspiration toward efficiency, to promote the optimum administration of justice by balancing against each other the first two goals, accuracy and fairness. And as in the Alexandre Dumas novel The Three Musketeers, the three principal arbitral duties find themselves joined by a fourth, which entails arbitrator vigilance in promoting an enforceable award. An inherent rivalry often permeates the various duties as implemented in practice. Hearing additional witnesses may promote fairness and accuracy at the expense of adding time and cost. Suggesting that counsel consider some new legal theory may promote a fuller right to be heard, but at the risk of creating a perception that an arbitrator favors one side or the other. Although experienced arbitrators may sometimes exercise their discretion so as to avoid conflict, many tensions resist facile analysis and easy resolution. Particularly when a contract stipulates an applicable law at odds with mandatory norms of a relatively foreseeable enforcement forum, serving more than one master can prove problematic. When considered together, the four arbitral duties often operate in anything other than the "all for one" spirit of the Musketeers' original motto.

1. DES GUIDELINES AFIN DE COMBLER LES LACUNES - 2. NI TOUS POUR UN, NI UN POUR TOUS - 3. DEUX RÉCENTES DÉCISIONS: CARIBBEAN NIQUEL ET STOLT-NIELSEN - 4. LE DEVOIR DE RENDRE UNE SENTENCE INATTAQUABLE - 5. PEUT-ON SERVIR DEUX MAÎTRES?