Summary

A dissenting opinion of one or several judges forming a minority may also be characteristic of arbitral tribunals in addition to independent courts belonging to the national judicial system. However, a dissenting opinion may be adopted not only by judges but also by minority members of other collegial decision-making bodies, including those exercising the function of extrajudicial adjudication. Analysing the statutes of international arbitral tribunals and the Estonian law, the author examines the possibilities of dissenting opinions and their communication in arbitral tribunals and in other above-mentioned bodies, including public administration, and in the parliamentary law. The author also explores if there is an automatic need for disclosure of a dissenting opinion, on what grounds a dissenting opinion should be allowed, and what are its effects and implications.