The purpose of the thesis is to analyse the root causes of the asymmetric nature
of investor-state arbitration and how it is reflected in the international law instruments
of investment protection, as well as the prospects of imposing obligations on investors,
especially in the human rights and environment sectors. The ultimate goal is to present
a mechanism of counterclaims as a way to improve the imbalances of the investor-state
arbitration, as well as to avoid the regulatory chill effect on the host states.