Writing a well-reasoned arbitration Award requires more than an understanding of the law. An arbitrator must be able to identify the issues in dispute, assess and weigh evidence, analyse the parties’ submissions, apply the law to the facts, reach logical conclusions, and communicate those conclusions through a clear, reasoned and enforceable Award.
Ciarb Kenya’s Module 3 – Evidence, Decision-Making & Award Writing is designed to equip candidates with the knowledge and practical skills required to undertake these essential aspects of the arbitral process.
About the Course
The programme runs over approximately three months and consists of three one-day online tutorials, supported by an optional revision session, followed by a four-hour Award Writing Examination.
Course Schedule
- Tutorial 1: 11 September 2026
- Tutorial 2: 13 October 2026
- Tutorial 3: 2 November 2026
- Revision Tutorial: 26 November 2026 (Optional – 1 hour)
- Examination: 4 December 2026
The tutorials will comprise lectures, discussions and guided learning based on the course Workbook, which will be issued upon completion of the application process.
What Will You Learn?
The course focuses on the practical processes an arbitrator follows when preparing and delivering an arbitration Award.
Participants will explore how to:
- Identify and define the issues that must be determined.
- Consider and evaluate evidence presented by the parties.
- Assess the burden and standard of proof.
- Analyse submissions and applicable law.
- Apply the law to the evidence before the tribunal.
- Reach logical and legally sound conclusions.
- Structure and write a clear, reasoned and enforceable Award.
- Address costs, interest, fees and expenses within an Award.
- Ensure that the Award complies with relevant legal requirements.
Course Content
Evidence
Participants will develop an understanding of key principles relating to evidence in arbitration, including:
- Basic concepts and types of evidence.
- Burden and standard of proof.
- Hearsay.
- Privilege.
- Written evidence and disclosure of documents.
- Witnesses.
- Expert witnesses.
Award Writing
A significant component of the programme focuses on the preparation of an effective arbitration Award. Topics include:
- The purpose of an Award.
- The importance of using plain language.
- Legal and substantive requirements.
- Identifying issues for determination.
- Reasons and decision-making.
- Structure and form of an Award.
- Publishing the Award.
Who Is This Course For?
This course is particularly suitable for individuals who:
- Are currently classified as Members of the Chartered Institute of Arbitrators and have attained the required membership cadre.
- Wish to develop a better understanding of evidence, decision-making and Award writing.
- Participate in arbitration as a party, party representative or witness.
- Want to strengthen their knowledge of arbitration law and practice, whether or not they intend to sit the examination.
- Are seeking to progress towards Fellowship of Ciarb.
Domestic Arbitration Pathway and International Arbitration
One of the most important things to understand about this course is that following this Ciarb pathway does not limit you to domestic arbitration.
The pathway provides a structured route for developing arbitration knowledge, professional competence and experience as you progress through Ciarb’s professional membership framework. Module 3 specifically focuses on Evidence, Decision-Making and Award Writing, with the examination based on the English Arbitration Act 1996.
What Is the Difference?
Domestic arbitration generally involves disputes connected to a particular jurisdiction and governed by the relevant domestic arbitration legislation.
International arbitration, by contrast, involves an international element — for example, parties from different jurisdictions, cross-border transactions or disputes, or other circumstances that give the dispute an international character. International arbitration may involve international arbitration institutions and rules, different national laws, international conventions and complex cross-border procedural and enforcement considerations.
International arbitration may therefore require additional knowledge and experience in areas such as:
- International arbitration rules and institutions.
- Cross-border commercial disputes.
- Jurisdiction and applicable law.
- International enforcement of arbitral Awards.
- International conventions and treaties.
- Cross-border evidence and procedural issues.
- Complex multi-jurisdictional disputes.
Will This Pathway Prevent You from Practising International Arbitration?
Absolutely not.
Completing this pathway does not prevent you from developing a career or practising in international arbitration. It should be viewed as a professional development pathway, not a limitation on your future practice.
In fact, many of the skills developed through Module 3 are highly relevant to international arbitration. The ability to:
- Evaluate evidence;
- Identify and structure issues;
- Analyse submissions;
- Apply legal principles to evidence;
- Make logical and reasoned decisions; and
- Write clear and effective Awards
are fundamental skills for arbitrators regardless of whether the dispute is domestic or international.
Candidates interested in international arbitration can build on this foundation through further specialist training, international arbitration experience, exposure to international institutions and rules, and participation in cross-border disputes.
The Pathway Is a Foundation, Not a Limitation
Think of the Ciarb pathway as building your arbitration foundation step by step.
Completing Module 3 can strengthen your professional knowledge and support your progression towards Fellowship of the Chartered Institute of Arbitrators, while leaving you free to develop your career in the direction that best suits your professional goals.
Your future practice may include domestic arbitration, international arbitration, mediation, dispute resolution advisory work, party representation or other areas of ADR.
The pathway gives you a foundation. It does not define the limits of your arbitration career.
Entry Requirements
To register for Module 3, candidates must meet one of the following requirements:
- Successfully complete and pass Ciarb Module 1 – Law, Practice and Procedure under the New Pathways Programme; or
- Successfully undertake the Special Process & Procedure Transition; or
- Successfully complete and pass Ciarb Module 2 – Law of Obligations under the New Pathways Programme, or Module 1 under the Old Pathways; or
- Receive an exemption from Ciarb Module 2 – Law of Obligations after successfully passing the exemption test.
Participants must also have regularised their Ciarb membership before registering for the course.
Learning Outcomes
On successful completion of the course, candidates will be able to demonstrate sound conceptual, technical and practical knowledge in:
- Recognising and evaluating evidence.
- Identifying issues arising from parties’ submissions.
- Structuring an Award to address all relevant issues.
- Making decisions logically and in accordance with the law.
- Writing Awards accurately and effectively.
- Understanding the discursive and operative parts of an Award.
- Dealing with costs and interest.
- Allocating the arbitrator’s fees and expenses.
- Ensuring compliance with legal and other requirements for an enforceable Award.
Assessment
Assessment will take the form of a four-hour Award Writing Examination.
Candidates must achieve a minimum overall mark of 70% to pass the course.
Successful Candidates
Successful candidates will:
- Receive an Advanced Certificate; and
- Become eligible to apply for and undertake the Peer Interview as part of the process towards upgrading to Fellow status of Ciarb.
Course Fees
The tutorial fee is Kshs 65,000, inclusive of course materials.
Participants may pay the tutorial fee in instalments, provided that:
- A first instalment of Kshs 30,000 is paid on or before the stipulated closing date; and
- The balance is paid in full before commencement of the course.
Any additional postage or delivery costs for course materials will be borne by the participant.
Examination Fee
The examination fee is:
GBP 412 for candidates depositing into the Kenya Branch NCBA Pounds Account.
Examination fees may also be paid by instalments, provided that all instalments are cleared before the stipulated deadline. Candidates wishing to use an instalment arrangement should contact the Branch Accounts Officer.
Payment Details
Tutorial Fee
Account Name: Chartered Institute of Arbitrators
Bank: NCBA Bank, Mama Ngina Branch
Account Number: 6435390017
M-Pesa Paybill: 975743
Account Reference: MOD3SEPT26
Examination Fee
Account Name: Chartered Institute of Arbitrators
Bank: NCBA Bank, Mama Ngina Branch
GBP Account Number: 6435390046
Course Materials
Course materials will be available for collection or delivery at the candidate’s cost upon payment of the course fees.
All participants are expected to have copies of the Arbitration Act 1996 and Arbitration Act 2025, which will be sent to you together with the reading Materials.
The examination will be based on the English Arbitration Act 1996.
Cancellation and Deferment
Cancellation charges will apply as follows:
| Notice Before Commencement | Refund |
|---|---|
| Over four weeks | 90% refund |
| Over two weeks | 50% refund |
| Less than one week | No refund |
Participants who wish to defer to the next training programme will have 10% of the course and/or assessment fees received deducted as deferment charges.
Take the Next Step in Your Arbitration Journey
Module 3 provides an important opportunity for aspiring and practising arbitrators to strengthen their ability to assess evidence, make sound decisions and produce professional arbitration Awards.
Whether your goal is to deepen your arbitration knowledge, improve your professional practice, progress towards Fellowship of the Chartered Institute of Arbitrators, or eventually develop your practice in international arbitration, this course provides an important foundation.
Your arbitration journey starts with building the right skills.
Join Ciarb Kenya for Module 3 – Evidence, Decision-Making & Award Writing and take the next step towards advanced arbitration practice: https://forms.gle/sQQyrgX5yz5e6L6f9


