Today, interim measures of protection form part of the regular litigation process Several reasons contribute to this. The main reason can be found in the long duration of court proceedings that call for interim solutions. But it is not only with litigation that the time span between the beginning of the d ispute and its resolution has increased in recent years; the same applies for international commercial arbitration According to Craig, Park and Paulsson(1990, pp 20-21), the average duration of International Chamber of Commerce (ICC)arbitrations is between one and two years The main reasons for the long duration of international commercial arbitrations lie in the special circumstances of the process. Among the special circumstances are the quently great geographical distances between the dramatis personae and the oord ination of the busy schedules of international arbitrators and party counsels. But the delay cannot only be attributed to inherent causes; it also finds its ground in the dilatory tactics applied by a party to which arbitration is not immune(Knoepfler, 1997 p 307). Thus, the need for interim solutions arises in arbitration as it does in commercial litigation Justice can only be done if efficient interim relief is available. Provisional remedies come under the principle that >justice is not to be evaded=(Andrews, 1994, p. 20) The means of recourse differ from country to country, but the system itself is regarded as >one of those general principles of law common to all legal systems=( Collins, 1994, p. 10). Interim relief, which has not received a legal definition, can be groupe as follows: To preserve the status quo in order to ensure enforcement, to shape the relationship between the parties during the process of dispute settlement and to preserve evidence(see Knoepfler and Schweizer, 1984, pp. 223-224, with reference German doctrine). It is hardly possible to make general remarks as to the kind of provisional remedies that is likely to be needed for what kind of legal relationships. It depends on the special circumstances of each individual case. Thus it is important to have the whole armoury of interim measures at hand once the need for them arises The impact of interim relief for the well-functioning of any method of adjud ication can be illustrated with regard to Mareva injunctions(after The Mareva). Mareva injunctions prevent the dissipation of assets. If such a mechanism would not be available for the time that passes until final ad judication takes place the winning party would only obtain a >Pyrrhic victory=(Van den Berg, 1981, p. 143) 3. The three main issues The three main issues are the relationship between court-ordered interim relief and arbitration, the competence of the arbitrator to order such measures and the enforcement of the arbitrator=s orders. The following expositio theoretical aspects of the three issues and discusses them broadly 3. 1 The relationship between court-ordered interim relief and arbitration 3.1.1 Underlying concepts Interim relief in arbitration is an interface between private dispute settlement and the court. It is one of these aspects of arbitration procedure that cannot escape court interference. The arbitrator has no power to enforce his orders. As the effectiveness of an interim measure of protection depends, in the end on its enforceability, court support may be needed. The critical question is how best to shift interim measures of protection with their need for enforcement sanctions to the realm of arbitrationToday, interim measures of protection form part of the regular litigation process. Several reasons contribute to this. The main reason can be found in the long duration of court proceedings that call for interim solutions. But it is not only with litigation that the time span between the beginning of the dispute and its resolution has increased in recent years; the same applies for international commercial arbitration. According to Craig, Park and Paulsson (1990, pp. 20-21), the average duration of International Chamber of Commerce (ICC) arbitrations is between one and two years. The main reasons for the long duration of international commercial arbitrations lie in the special circumstances of the process. Among the special circumstances are the frequently great geographical distances between the dramatis personae and the coordination of the busy schedules of international arbitrators and party counsels. But the delay cannot only be attributed to inherent causes; it also finds its ground in the dilatory tactics applied by a party to which arbitration is not immune (Knoepfler, 1997, p. 307). Thus, the need for interim solutions arises in arbitration as it does in commercial litigation. Justice can only be done if efficient interim relief is available. Provisional remedies come under the principle that >justice is not to be evaded= (Andrews, 1994, p. 20). The means of recourse differ from country to country, but the system itself is regarded as >one of those general principles of law common to all legal systems= (Collins, 1994, p. 10). Interim relief, which has not received a legal definition, can be grouped as follows: To preserve the status quo in order to ensure enforcement, to shape the relationship between the parties during the process of dispute settlement and to preserve evidence (see Knoepfler and Schweizer, 1984, pp. 223-224, with reference to German doctrine). It is hardly possible to make general remarks as to the kind of provisional remedies that is likely to be needed for what kind of legal relationships. It depends on the special circumstances of each individual case. Thus it is important to have the whole armoury of interim measures at hand once the need for them arises. The impact of interim relief for the well-functioning of any method of adjudication can be illustrated with regard to Mareva injunctions (after The Mareva). Mareva injunctions prevent the dissipation of assets. If such a mechanism would not be available for the time that passes until final adjudication takes place, the winning party would only obtain a >Pyrrhic victory= (Van den Berg, 1981, p. 143). 3. The three main issues The three main issues are the relationship between court-ordered interim relief and arbitration, the competence of the arbitrator to order such measures and the enforcement of the arbitrator=s orders. The following exposition focuses on theoretical aspects of the three issues and discusses them broadly. 3.1 The relationship between court-ordered interim relief and arbitration 3.1.1 Underlying concepts Interim relief in arbitration is an interface between private dispute settlement and the court. It is one of these aspects of arbitration procedure that cannot escape court interference. The arbitrator has no power to enforce his orders. As the effectiveness of an interim measure of protection depends, in the end, on its enforceability, court support may be needed. The critical question is how best to shift interim measures of protection with their need for enforcement sanctions to the realm of arbitration