ACERCAMIENTO AL PROCEDIMIENTO PROBATORIO DE LAS REGLAS DE PRAGA DESDE LA CULTURA JURÍDICA DEL CIVIL LAW.

The Prague Rules has been presented as civil law's rules on the taking of evidence in international arbitration. It has been defended that the Prague Rules are a disruptive alternative regarding the IBA Rules. The aim of this paper is check if the Prague Rules are part of civil law. To do this, we will compare the Prague Rules with the Spanish Civil Procedure Act, the Spanish Arbitration Act, the Code of Best Practices in Arbitration of the Spanish and Ibero-American Arbitration Club, and the IBA Rules. The answer of this paper will reveal that the Prague Rules are part of civil law, but they are not a really innovation about evidence procedure in international arbitration. [ABSTRACT FROM AUTHOR]