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Glossary

Mediation & ADR glossary

Alternative dispute resolution (ADR) covers the processes used to resolve disputes outside formal court proceedings. This glossary covers 40 commonly used terms across mediation, arbitration, and expert determination in the Australian context.

In short

This is a glossary of 40 key terms used in Australian alternative dispute resolution practice. Each entry has a plain-English definition and, where relevant, a citation to the governing Act or rules.

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40 terms

Definitions

ACICA

The Australian Centre for International Commercial Arbitration — a leading Australian arbitral institution that administers arbitrations under its own rules.

Ad hoc arbitration

An arbitration conducted without the administration of an institution, with the parties and tribunal managing the process directly.

Agreement to mediate

A written agreement between parties setting out the terms of the mediation, typically signed before the process begins.

Arb-Med

A hybrid process in which an arbitrator is authorised to act as a mediator, and if mediation fails, return to arbitration.

Commercial Arbitration Act 2010 (NSW) s 27D

Arbitral award

A final and binding decision of an arbitral tribunal resolving the dispute between the parties.

Commercial Arbitration Act 2010 (NSW) s 31

Arbitral tribunal

The sole arbitrator or panel of arbitrators appointed to determine the dispute.

Commercial Arbitration Act 2010 (NSW) s 10

Arbitration

A consensual, private dispute resolution process in which the parties submit their dispute to a neutral tribunal for a binding determination.

Commercial Arbitration Act 2010 (NSW)

Arbitration agreement

An agreement by the parties to submit a present or future dispute to arbitration, which may be contained in a contract clause or a separate document.

Commercial Arbitration Act 2010 (NSW) s 7

Authority to settle

The scope of the representative's mandate at a mediation to bind the client to a settlement agreement.

Binding determination

An outcome of a dispute resolution process that legally binds the parties, such as an arbitral award or court judgment.

Calderbank offer

A without-prejudice offer to settle marked as reserving the right to bring it to the court's attention on the question of costs if the recipient does worse at trial.

Calderbank v Calderbank [1975] 3 All ER 333

Case management

The procedural conduct of a dispute, including the setting of timelines, disclosure, and evidence orders.

Caucus

A private session between the mediator and one party (or their lawyer) held separately from the other party, used to explore positions and options.

Co-mediation

Mediation conducted by two or more mediators working together, often used in cross-cultural or multi-party disputes.

Commercial Arbitration Act

The uniform state legislation (based on the UNCITRAL Model Law) governing domestic commercial arbitration in Australia.

Commercial Arbitration Act 2010 (NSW)

Confidentiality

The undertaking of parties and the mediator or tribunal to keep the proceedings and materials confidential, usually reinforced by agreement and statute.

Commercial Arbitration Act 2010 (NSW) s 27E

Early neutral evaluation

A non-binding process in which a neutral evaluator gives an assessment of the merits of each party's case to encourage settlement.

Enforcement

The process by which an arbitral award or settlement agreement is given legal effect, typically by leave of a court.

Commercial Arbitration Act 2010 (NSW) s 35

Expert determination

A contractually agreed process in which an independent expert determines a specified issue (such as valuation), usually binding as a matter of contract.

Facilitative mediation

A mediation style in which the mediator facilitates discussion and negotiation without evaluating the merits or proposing solutions.

Heads of agreement

A short-form document recording the key terms of a settlement reached at mediation, often signed before a full settlement deed is drafted.

Impartiality

The obligation of a mediator or arbitrator to be free from bias and to treat the parties fairly and equally.

Commercial Arbitration Act 2010 (NSW) s 12

Independence

The absence of relationships or interests that could affect a mediator's or arbitrator's objectivity.

Commercial Arbitration Act 2010 (NSW) s 12

Institutional arbitration

An arbitration administered by an institution (such as ACICA or the ICC) under its published rules.

International Arbitration Act

The Commonwealth Act governing international arbitration in Australia, incorporating the UNCITRAL Model Law.

International Arbitration Act 1974 (Cth)

Med-Arb

A hybrid process in which the parties first attempt mediation and, if unsuccessful, the dispute is determined by arbitration (often with the same neutral).

Mediation

A voluntary and confidential process in which an impartial mediator assists the parties to reach a negotiated settlement.

Mediator

A neutral third party who facilitates communication between the parties in a mediation, without imposing a decision.

Model Law

The UNCITRAL Model Law on International Commercial Arbitration, adopted as the basis for domestic and international arbitration in Australia.

International Arbitration Act 1974 (Cth) s 16

New York Convention

The 1958 United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, implemented in Australia by the International Arbitration Act.

International Arbitration Act 1974 (Cth) Part II

NMAS

The National Mediator Accreditation System — the national scheme for accrediting mediators in Australia.

Non-binding opinion

A written assessment by a neutral expert or early evaluator that is not legally binding but may inform settlement discussions.

Party autonomy

The principle that parties to an arbitration or ADR process are free to agree on its procedural rules, seat, and applicable law.

Commercial Arbitration Act 2010 (NSW) s 19

Procedural order

An order of an arbitral tribunal dealing with the procedural conduct of the arbitration, such as timetables and disclosure.

Seat of arbitration

The legal place of the arbitration, which determines the supervisory jurisdiction and applicable procedural law.

Commercial Arbitration Act 2010 (NSW) s 20

Settlement deed

A formal written agreement recording the terms of settlement, typically with release and indemnity clauses.

Shuttle mediation

A mediation technique in which the mediator moves between parties in separate rooms rather than holding joint sessions.

Terms of settlement

A written document recording the terms on which parties have resolved their dispute, usually signed at the conclusion of mediation.

Without prejudice

A label applied to communications made in genuine attempts to settle a dispute, which generally prevents them from being used as evidence of admissions.

Evidence Act 1995 (Cth) s 131

Writ of enforcement

A court order giving effect to a judgment, arbitral award, or settlement, permitting enforcement steps such as seizure of property.

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This glossary is a general reference for practitioners — not legal advice. Always verify against the applicable Commercial Arbitration Act and procedural rules.

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