Emergency Arbitration in 2025 BANI Rules: an Effective Measure for Construction Arbitration in Indonesia?

1. Introduction
   In recent times, the Badan Arbitrase Nasional Indonesia (“BANI”) has published its latest 2025 Arbitration Rules and Procedures (“BANI Rules”). Although the 2025 BANI Rules lacks a release date and does not explicitly specify an official effective date, BANI has confirmed that cases submitted to BANI on or after 2 January 2025 will be governed by the 2025 BANI Rules.¹The 2025 BANI Rules introduces several adjustments and advancements in order to align the Indonesian arbitration with the international arbitration practices, namely: (i) adjustment to consolidation, multiparty, and multicontract arbitration, (ii) expanded grounds for challenging arbitrators, and (iii) emergency arbitration.² One particular advancement which is important to be highlighted in this 2025 BANI Rules is the newly-introduced emergency arbitration, a new concept for Indonesian arbitration as it was absent from previous BANI Rules.

   The concept of emergency arbitration was firstly introduced in 1990 by the International Chamber of Commerce (“ICC”) with the term of pre-arbitral referee, and later on, in mid-1990s by the World Intellectual Property Organization (WIPO) with the term of emergency relief.³ In 1999, the American Arbitration Association (AAA) adopted the concept of emergency arbitration with the term of emergency measures of protection, and later on, its international division, the International Center for Dispute Resolution (“ICDR”) introduced the term of emergency arbitration in 2006.⁴ Afterwards, the 2012 ICC Rules inherently adopted the same provisions of emergency arbitration as that of the ICDR, where an emergency arbitrator can be appointed when a party needs urgent interim or conservatory measures that cannot wait the constitution of an arbitral tribunal.⁵

   Today, the concept of emergency arbitration has gained considerable prominence and has already been incorporated in most of leading arbitral institutions, such as the Singapore International Arbitration Center (“SIAC”), the London Court of International Arbitration (LCIA), the Hong Kong International Arbitration Center (HKIAC), and the Beijing Arbitration Commission (BAC).⁶

   Under the 2025 BANI Rules, emergency arbitration is stipulated in paragraph (5) of Article 17, an additional paragraph which was not yet existed before. This allows a party seeking urgent interim or conservatory measures prior to the constitution of the arbitration tribunal to apply for emergency arbitration,⁷ with the purpose to seek an urgent temporary relief from an emergency arbitrator. This is particularly useful in situations where waiting for the full arbitral tribunal to be formally constituted would cause a party to suffer any irreparable harm.

   This article aims to discuss about the concept of emergency arbitration in Indonesian arbitration based on the 2025 BANI Rules while comparing it with the provisions of the same under the 2025 SIAC Rules and 2021 ICC Rules, and to what extent does the concept of emergency arbitration would be an effective measure for the resolution of construction arbitration in Indonesia.

2. Discussion
   1. Emergency Arbitration Under 2025 BANI Rules Compared with 2025 SIAC Rules and 2021 ICC Rules
      Arbitration in Indonesia is stipulated under Law No. 30 of 1999 on Arbitration and Alternative Dispute Resolution (“Law 30/1999”). While emergency arbitration is a welcome addition however, the Law 30/1999 has not yet been amended to accommodate the concept of emergency arbitration and its procedure. In some jurisdictions, such as Singapore and Hong Kong, legislative amendments were introduced before, or right after, arbitration institutions would formally adopted emergency arbitration procedures, in order to ensure a clear legal basis for award enforcement.Aside from the formulation under Article 17 paragraph (5), emergency arbitration under the 2025 BANI Rules is further stipulated in Attachment I on Emergency Arbitration Rules (“Emergency Arbitration Rules”). Article 1 paragraph (1) of the Emergency Arbitration Rules stipulates that a party who needs an emergency arbitration shall submit its application to the Secretariat of BANI.⁸ The Chairman of BANI holds the discretion to agree or reject an emergency arbitration application. If agreed, the Secretariat of BANI shall send a copy of the application including the documents to the responding party. If rejected however, the Secretariat of BANI shall send a notice to the parties.⁹

      Once the emergency arbitration application is accepted, the Chairman shall appoint a sole emergency arbitrator within 2 (two) calendar days since the receipt of the application. The appointed emergency arbitrator shall not act as an arbitrator for the parties’ dispute in the arbitration tribunal.¹⁰ The parties may challenge the appointment of the emergency arbitrator if circumstances exist that give rise to the alleged lack of impartiality or independence,¹¹ which shall be submitted to the Chairman of BANI within 2 (two) calendar days since the receipt of notice of appointment of the sole emergency arbitrator by the Chairman of BANI. Furthermore, the other party and the emergency arbitrator shall give its written response within 2 (two) calendar days since the receipt of notice of challenge. The decision-making responsibility would fall to the hand of the Chairman of BANI, where it shall issue its decision within 4 (four) calendar days since the receipt of written response.¹²

      One point to note regarding the timeframe of emergency arbitration under the 2025 BANI Rules is potential issue when, for example, the notice of appointment of the sole emergency arbitrator by the Chairman of BANI is received on a Friday. Then, a party shall submit a challenge within 2 (two) calendar days which falls on a Sunday, which is not a business day. Therefore, it would be impractical and even harm such party’s rights to file a challenge. BANI confirmed that if a deadline of a timeframe falls on a Saturday, Sunday or a public holiday, then the deadline would be extended to the next business day,¹³ even though there are no such provision. To avoid any misunderstanding, an amendment to this particular part of the 2025 BANI Rules might be needed for better clarity and legal certainty for the disputing parties.

      Once the appointment of the emergency arbitrator is set and clear, the first proceeding shall be conducted at the latest 3 (three) calendar days since the appointment of the sole emergency arbitrator by the Chairman of BANI, or after the challenge procedure has been completed, if any. The parties must adhere to the schedule of proceedings. The emergency arbitrator is obliged to comply with the principle of audi et alteram partem,¹⁴ where it shall give the same opportunities to the parties in presenting their case. The responding party is entitled to raise an objection, such as the emergency arbitrator does not have competence or the arbitration agreement is invalid, whereas such objections shall be decided by the emergency arbitrator.¹⁵

      The length of the emergency arbitration proceeding is 14 (fourteen) calendar days since the appointment of the emergency arbitrator by the Chairman of BANI, or after the challenge procedure has been completed, if any. The emergency arbitrator however, may extend the time limit for maximum 7 (seven) calendar days if deemed necessary under legitimate grounds. The emergency arbitrator may issue its award with the conditions that it thinks fit, provided that it is in written form, duly dated, and signed, whilst stating the reasons upon which it is based.¹⁶ 2025 BANI Rules is silent on the timeframe of registration of emergency award. Nevertheless, pursuant to Article 59 paragraph (1) of Law 30/1999, within no later than 30 (thirty) days from the date the award is pronounced, the original copy or an authentic duplicate of the award shall be submitted and registered by the arbitrator or their representative with the clerk of district court.¹⁷

      The emergency arbitrator’s award shall be final and binding on the parties. Furthermore, the parties agree to implement the award in due time and immediately. Aside from the obligation to implement the award, the parties agree to waive the right to file for appeal, review or other measures to the district court in relation to the emergency arbitrator’s award.¹⁸

      In the event that the losing party is not willing to implement the emergency arbitrator’s award in due time and immediately, then the provisions on the implementation of arbitral awards under Articles 62 to 64 of Law 30/1999 and Articles 8 to 15 of Supreme Court Regulation No. 3 of 2023 on Procedures for Appointing Arbitrators by the Court, Right of Recusal, Examination of Requests for Enforcement and Cancellation of Arbitration Awards (“Supreme Court Reg. 3/2023”) shall apply. The emergency arbitrator’s award, as a final and binding award in its nature, shall be implemented via an order from a head of district court based on an application by a party, as stipulated under Article 61 of Law 30/1999.¹⁹ The order of the head of district court to enforce the emergency arbitrator’s award if the parties do not implement it voluntarily, must be given within a maximum of 30 (thirty) days after the application for execution is registered with the clerk of district court.²⁰ The order of the head of district court shall be written in the original and authentic copy of the emergency arbitrator’s award.²¹ The emergency arbitrator’s award that has been marked with an order from the head of district court is implemented in accordance with the provisions for implementing decisions in civil cases for a final and binding decision.²²

      Furthermore, the applicant shall pay the costs of the emergency arbitration in full amount when the application of the emergency arbitration is filed.²³ The Emergency Arbitration Rules is silent on the allocation of emergency arbitration costs. Nevertheless, pursuant to: (i) Article 77 paragraph (1) of Law 30/1999, the arbitration costs are charged to the losing party,²⁴ and (ii) Article 36 of 2025 BANI Rules, the arbitrator shall have the authority to determine which party or parties shall be responsible for payment or reimbursement to the other party, for the whole or any part of the costs, which allocation shall be made a part of the award.²⁵ Lastly, to prevent any absence of rules, the Chairman of BANI is entitled to make rules in relation to the initiation of emergency arbitration which is not yet expressly provided in the Emergency Arbitration Rules.²⁶

      The inclusion of emergency arbitration under 2025 BANI Rules aligns with the modern progress of international arbitration, reflecting BANI’s commitment to improve efficiency of dispute resolution. Nevertheless, there are a few key points which shall be highlighted from the provisions of emergency arbitration under 2025 BANI Rules, while compared with the provisions of the same under 2025 SIAC Rules and 2021 ICC Rules, provided in the following.

      Matter	2025 BANI Rules 27	2025 SIAC Rules 28	2021 ICC Rules29
      Availability	Yes, under Article 17 paragraph (5) and Attachment 1.	Yes, under Rule 12 and Schedule 1.	Yes, under Article 29 and Appendix V.
      Term	Emergency Arbitration	Emergency Interim or Conservatory Relief	Emergency Measure
      Length of Proceeding	The length of proceeding is 14 days since the appointment of the emergency arbitrator.	Emergency arbitrator must issue an order or award within 14 days after its appointment.	Emergency arbitrator must issue an order no later than 15 days from the date on which the file was transmitted to it.
      Proceeding Extension	Yes, extendable subject to the discretion of the emergency arbitrator up to 7 days.	Yes, extendable subject to the discretion of the Registrar.	Yes, extendable subject to the discretion of the President.
      Form of Outcome	Award	Order or Award	Order
      Binding Nature	Final and binding, interim or conservatory in nature.	Binding, but may cease to be binding on certain circumstances.	Binding, but may cease to be binding on certain circumstances.
      Impact on Main Tribunal	It is unclear whether:a.     the main tribunal may or may not affirm, reconsider, modify, or vacate the emergency arbitrator’s award; and b.    it will cease to be binding upon the main tribunal final award.	The main tribunal may affirm, reconsider, modify, or vacate the order or award, and it will cease to be binding upon issuance of the final award, unless the main tribunal determines otherwise.	Will cease to be binding upon the main tribunal final award, unless the main tribunal decides otherwise.

      Table 1. Comparison of Emergency Arbitration Provisions in 2025 BANI Rules, 2025 SIAC Rules, and 2021 ICC Rules.

      Based on the comparison of emergency arbitration provisions in 2025 BANI Rules with 2025 SIAC Rules and 2021 ICC Rules above, there are a few points that might need improvement on how the concept of emergency arbitration is stipulated under the 2025 BANI Rules. One point is the final and binding nature of the emergency arbitrator’s award. Article 7 paragraph (1) of Attachment I of the 2025 BANI Rules stipulated that the emergency arbitrator’s award shall be final and binding on the parties. It is not clear however, to what extent does the emergency arbitrator’s award shall be final and binding, since it is not explicitly stipulated under the 2025 BANI Rules. While the 2025 SIAC Rules and 2021 ICC Rules stipulated that an emergency award or order may cease to be binding on the parties on certain circumstances, such as upon issuance of the final award, unless the tribunal determines otherwise.³⁰ Even though it is not explicitly stipulated, the nature of the emergency arbitrator’s award itself is interim or conservatory, as reflected in Article 17 paragraph (5) of the 2025 BANI Rules. Thus, it should not stand on its own, let alone contradict the final award. Therefore, it should be interpreted that the emergency arbitrator’s award will only temporarily bind the parties until the issuance of the final award by the main tribunal. Thus, in the end, the only binding award for the disputing parties would be the final award. This is in line with the concept of interlocutory decision in a civil proceeding, where the judges can make or issue a decision that is not a final decision, which is issued during the examination process.³¹ The interlocutory decision cannot stand on its own, but rather as an integral part of the final decision regarding the merits of the case.³²

      Another point is that SIAC and ICC Rules entitle the main tribunal to affirm, reconsider, modify, or vacate any order or award issued by the emergency arbitrator.³³ 2025 SIAC Rules is silent on when the main tribunal may implement it. Nevertheless, pursuant to Rule 51.1 of 2025 SIAC Rules, the main tribunal may make more than one award at different points in time during the arbitration on different aspects of the matters to be determined.³⁴ Therefore, it might be interpreted that the main tribunal may affirm, reconsider, modify, or vacate any order or award issued by the emergency arbitrator in its final award, or at any time during the arbitration at the request of a party for interim or conservatory relief, if deemed appropriate.³⁵ In contrast, the 2025 BANI Rules does not include any stipulation where the main tribunal would be entitled to affirm, reconsider, modify, or vacate the emergency arbitrator’s award. Therefore, for better clarity and legal certainty for the disputing parties, the 2025 BANI Rules may adopt the stipulation of the 2025 SIAC Rules where the main tribunal may affirm, reconsider, modify, or vacate the emergency arbitrator’s award subsequently in its final award, or at any time during the arbitration at the request of a party for interlocutory or interim award.

      Therefore, to align the concept of emergency arbitration under the 2025 BANI Rules with international practices where the main tribunal retains authority over interim measures as well as to ensure clarity and legal certainty for the disputing parties, BANI may include the following stipulations: (i) the deadline of a timeframe would be extended to the next business day if a deadline falls on a Saturday, Sunday, or public holiday, or to revise “calendar days” to “business days” (ii) the main tribunal may affirm, reconsider, modify, or vacate the emergency arbitrator’s awards, and (iii) that the emergency arbitrator’s awards will cease to be binding on certain circumstances, for instance, upon the issuance of the main tribunal’s final award.

   2. The Effectivity of Emergency Arbitration for Construction Arbitration in Indonesia
      Emergency arbitration is a newly-established legal procedure under the 2025 BANI Rules which allows a party in a dispute to seek an urgent interim relief before a full arbitral tribunal is formally constituted. One of the key features of emergency arbitration is speed. It provides a fast-track procedure to obtain interim measures before the main arbitration begins. Specifically, under the 2025 BANI Rules, the length of the emergency arbitration proceeding is 14 (fourteen) days since the appointment of the emergency arbitrator, subject to extension for 7 (seven) more days.³⁶The fast-track procedure would be especially useful when immediate action is needed to preserve rights, assets, or evidence, to avoid greater losses, to secure evidence, or even to stop a party from transferring or hiding assets, and waiting for the constitution of full arbitral tribunal would cause irreparable damage to a party, which could be essential for construction disputes. Given the wide range of issues that can be classified as “construction disputes” and the differing levels of urgency often involved, practitioners in this field are likely to be among the most frequent users of emergency arbitration.³⁷

      In construction projects, seeking emergency relief is not uncommon. One can easily recognize that there will be numerous instances where emergency relief is required, and a party will not want to make its way through a possibly lengthy constitution of the full arbitral tribunal process. Whereas the constitution would be subject to the appointment of an arbitrator by the respondent in its response and also the challenge procedure, if any, and may be considered too lengthy depending on the nature of relief sought.³⁸ Such situations may arise in cases involving the invocation of a performance bond, whether for allegedly unpaid sums or defective work, requests for injunctions to prevent a contractor from abandoning the site, or applications for interim relief to preserve evidence or assets.³⁹ The specialized expertise of the arbitrator, the confidentiality of the process, and other factors discussed above can make emergency arbitration a more appealing option than seeking interim measures through national courts.⁴⁰

      A report on an emergency arbitration under the ICC Rules in relation to a substantial construction project in the Middle-East and North Africa (MENA) region highlights the effectiveness and efficiency of this process in construction disputes.⁴¹ It has been reported that after the claimant issued its application for emergency measures to the ICC, the emergency arbitrator was appointed within 48 (forty-eight) hours, and despite a request for extension of time for the respondent’s reply, the emergency arbitrator took a firm stand to adhere to the original timeline. Complying with the time limit set out in the ICC Rules, the emergency arbitrator issued an order in 7 (seven) days after the hearing, a total of 20 (twenty) days after the claimant’s application.⁴²

      The implementation of the emergency arbitration can protect the interest of one party’s financial interests in a speedy and fast-track procedure, while allowing the core issues to be resolved later by the full arbitral tribunal. For example, a multinational company (owner) is building a large commercial complex and has hired a contractor under a construction contract governed by BANI Rules. Midway through the project, the owner accuses the contractor of significant construction defects and delays. The owner threatens to terminate the contract and liquidate a Rp 10 billion performance bond provided by the contractor’s bank.

      In this case, the contractor, fearing financial damage and reputational harm, may file for emergency arbitration application (after filing the main arbitration claim) under the 2025 BANI Rules to request an interim relief to the emergency arbitrator to restrain the owner from liquidating the performance bond or bank guarantee until the full arbitral tribunal is constituted and issue a final award for the dispute, arguing that, among others, the contractor has not breached the contract, or the breach of contract is not simple and unclear whether it is on the contractor’s side, or the value of the bank guarantee and the value of losses before liquidation is still unclear.

      This example demonstrates how emergency arbitration can be crucial in high-stakes and time-sensitive construction disputes. Nevertheless, as a newly introduced concept under the 2025 BANI Rules, the implementation of emergency arbitration for construction disputes in Indonesia remains untested. As the concept of emergency arbitration continues to evolve in Indonesian arbitration, ongoing observation will be necessary to evaluate its practical effectiveness and determine whether it serves as a viable mechanism for urgent relief in construction arbitration proceedings.

3. Conclusion
   The introduction of emergency arbitration under the 2025 BANI Rules marks an important alignment of Indonesian arbitration with international arbitration, offering a streamlined mechanism for urgent relief. If compared to the concept of the same under the 2025 SIAC Rules and the 2021 ICC Rules however, there are a few proposed provisions that might be included in the 2025 BANI Rules to achieve better clarity and legal certainty for the disputing parties, namely, (i) the revision on more reasonable calendar days or revising “calendar days” to “business days”, (ii) the insertion of provision that the main tribunal may affirm, reconsider, modify, or vacate the emergency arbitrator’s awards, and (iii) the stipulation that the emergency arbitrator’s awards will cease to be binding on certain circumstances, for instance, upon the issuance of the main tribunal’s final award.The fast-track procedure of emergency arbitration is useful for construction arbitration where seeking emergency relief is not uncommon. A report on the implementation of emergency arbitration under the ICC Rules highlights the effectiveness and efficiency of this process in construction disputes. Nevertheless, the concept of emergency arbitration under the 2025 BANI Rules for construction disputes in Indonesia remains untested. Therefore, further observation is needed to evaluate its practical effectiveness.

Dhimas Haris Anggara Mukti

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References:
Laws & Regulations

Badan Arbitrase Nasional Indonesia. 2025. BANI Arbitration Center Arbitration Rules and Procedures. https://baniarbitration.org/arbitration-rules/.

International Chamber of Commerce. 2021. Arbitration Rules of International Court of Arbitration, 1 January 2021. ICC Publication DRS892 ENG. https://iccwbo.org/dispute-resolution/dispute-resolution-services/arbitration/rules-procedure/2021-arbitration-rules/.

Republic of Indonesia. 1999. Law on Arbitration and Alternative Dispute Resolution. Law No. 20 of 1999. 1999 State Gazette No. 138, Additional State Gazette No. 3872. https://peraturan.bpk.go.id/Details/45348/uu-no-30-tahun-1999/.

__________________ . 2023. Supreme Court Regulation on Procedures for Appointing Arbitrators by the Court, Right of Recusal, Examination of Requests for Enforcement and Cancellation of Arbitration Awards. Supreme Court Regulation No. 3 of 2023. 2023 State Gazette No. 827. https://peraturan.bpk.go.id/Details/277123/perma-no-3-tahun-2023/.

Singapore International Arbitration Centre. 2025. Arbitration Rules of the Singapore International Arbitration Centre, 7th Edition, 1 January 2025. https://siac.org.sg/siac-rules-2025/.

Books & Articles

Hannesian, Grant and Dosman, E. Alexandra. 2018. Songs of Innocence and Experience: Ten Years of Emergency Arbitration. American Review of International Arbitration, vol. 27. https://aria.law.columbia.edu/issues/27-2/songs-of-innocence-and-experience-ten-years-of-emergency-arbitration-vol-27-no-2/.

Harahap, M. Yahya. 2009. Hukum Acara Perdata: Gugatan, Persidangan, Penyitaan, Pembuktian, dan Putusan Pengadilan. Jakarta: Sinar Grafika.

Kumar, Shivam. 2022. Emergency Arbitration – Its Advantages, Challenges and Legal Status in India. SCC Times. https://www.scconline.com/blog/post/2022/03/26/emergency-arbitration/.

Levin, Ann, et. al. 2017. Emergency Arbitrators and Expedited Tribunals in Construction Disputes – Some Recent Experience. https://www.herbertsmithfreehills.com/insights/2017-05/inside-construction-and-infra/.

Markert, Lars and Rawal, Raeesa. 2020. Emergency Arbitration in Investment and Construction Disputes: An Uneasy Fit?. Journal of International Arbitration, vol. 37, issue 1. https://www.nishimura.com/en/knowledge/publications/20200201-26316/.

Rajah & Tann Asia. 2025. Understanding The 2025 BANI Rules: Key Changes and Their Impact. https://arbitrationasia.rajahtannasia.com/understanding-the-2025-bani-rules-key-changes-and-their-impact/.

Steindl, Barbara. 2012. The Emergency Arbitrator in International Construction Arbitration. Contemporary Issues in International Arbitration and Mediation. The Fordham Papers.

Wahyuni, Willa. 2023. Mengenal Putusan Sela dan Fungsinya. https://www.hukumonline.com/berita/a/ putusan-sela-lt6358f75b389e2/.

1. Rajah & Tann Asia, Understanding The 2025 BANI Rules: Key Changes and Their Impact (can be accessed in https://arbitrationasia.rajahtannasia.com/understanding-the-2025-bani-rules-key-changes-and-their-impact/, accessed on 9 April 2025 at 15.48 WIB).
2. Ibid.
3. Grant Hanessian and E. Alexandra Dosman, Songs of Innocence and Experience: Ten Years of Emergency Arbitration, American Review of International Arbitration, vol. 27, 2018, pp. 216-217.
4. Ibid.
5. Shivam Kumar, Emergency Arbitration – Its Advantages, Challenges and Legal Status in India, published as an op. ed. in SCC Times on 26 March 2022 (can be accessed in https://www.scconline.com/blog/post/ 2022/03/26/emergency-arbitration, accessed on 9 April 2025 at 16.23 WIB).
6. Lars Markert and Raeesa Rawal, Emergency Arbitration in Investment and Construction Disputes: An Uneasy Fit?, Journal of International Arbitration, vol. 37, issue 1, 2020, pp. 132-133.
7. Badan Arbitrase Nasional Indonesia, 2025 BANI Arbitration Center Arbitration Rules and Procedures, Article 17 paragraph (5).
8. Op. Cit., Attachment I on Emergency Arbitration Rules, Article 1 paragraph (1).
9. Op. Cit., Attachment I, Article 1 paragraph (4).
10. Op. Cit., Attachment I, Article 2.
11. Op. Cit., Article 12 paragraph (1).
12. Op. Cit., Attachment I, Article 3.
13. This information is retrieved based on a phone call discussion with the representative of BANI which is conducted on 21 April 2025.
14. Audi et alteram partem is a fundamental principle of natural justice and the cornerstone of fairness and due process which ensures that everyone involved in a legal matter, or a decision that could affect them, is given a fair hearing and the chance to respond to evidence against them before a decision is made.
15. BANI, 2025 BANI Rules, Attachment I, Article 5.
16. Op. Cit., Attachment I, Article 6.
17. Republic of Indonesia, Law on Arbitration and Alternative Dispute Resolution, Law No. 20 of 1999, 1999 State Gazette No. 138, Additional State Gazette No. 3872, Article 59 paragraph (1).
18. BANI, 2025 BANI Rules, Attachment I, Article 7.
19. Republic of Indonesia, Law on Arbitration, Article 61. See also: Republic of Indonesia, Supreme Court Regulation on Procedures for Appointing Arbitrators by the Court, Right of Recusal, Examination of Requests for Enforcement and Cancellation of Arbitration Awards, Supreme Court Regulation No. 3 of 2023, 2023 State Gazette No. 827, Article 8 paragraph (1).
20. Op. Cit., Article 62.
21. Op. Cit., Article 63. See also: Republic of Indonesia, Supreme Court Regulation on Procedures for Appointing Arbitrators by the Court, Article 9.
22. Op. Cit., Article 64. See also: Republic of Indonesia, Supreme Court Regulation on Procedures for Appointing Arbitrators by the Court, Article 14.
23. BANI, 2025 BANI Rules, Attachment I, Article 8.
24. Republic of Indonesia, Law on Arbitration, Article 77 paragraph (1).
25. BANI, 2025 BANI Rules, Article 36.
26. Op. Cit., Attachment I, Article 9.
27. Op. Cit. Attachment I.
28. Singapore International Arbitration Centre, Arbitration Rules of the Singapore International Arbitration Centre, 7^th Edition, 1 January 2025. Schedule 1.
29. International Chamber of Commerce, Arbitration Rules of International Court of Arbitration, 1 January 2021. ICC Publication DRS892 ENG. Appendix V.
30. SIAC, 2025 SIAC Rules, Schedule 1, Rule 20. See also: ICC, 2021 ICC Rules, Appendix V, Article 6 paragraph (6).
31. M Yahya Harahap, Hukum Acara Perdata: Gugatan, Persidangan, Penyitaan, Pembuktian, dan Putusan Pengadilan (2009, Jakarta: Sinar Grafika), pp. 880.
32. Willa Wahyuni, Mengenal Putusan Sela dan Fungsinya, (can be accessed in https://www.hukumonline.com/berita/a/ putusan-sela-lt6358f75b389e2/, accessed on 22 April 2025 at 09.30 WIB).
33. SIAC, 2025 SIAC Rules, Schedule 1, Rule 21.
34. Op. Cit., Rule 51.1.
35. Op. Cit., Rule 45.1.
36. BANI, 2025 BANI Rules, Attachment I, Article 6 paragraph (2).
37. Lars Markert and Raeesa Rawal, Emergency Arbitration, pp. 138.
38. Ibid.
39. Op. Cit., pp. 139.
40. Ibid.
41. Ann Levin, et. al., Emergency Arbitrators and Expedited Tribunals in Construction Disputes – Some Recent Experience, (can be accessed in https://www.herbertsmithfreehills.com/insights/2017-05/inside-construction-and-infra, accessed on 15 April 2025 at 16.30 WIB).
42. Ibid.