Applicable Law, Arbitration Agreement, Conflict of Laws, France, French Law, International arbitration, Non-signatory, Third Party
A Third-Party, One Arbitration Agreement, Two Approaches: The French Courts’ Views on the Law Applicable to the Arbitration Agreement in Kabab-Ji v. Kout Food Group
Almost a decade after the Dallah saga, the French and English courts are once again considering the enforcement of the same award yet reaching conflicting solutions. On 29 March 2019, the High Court of England and Wales, followed on 20 January 2020 by the England and Wales Court of Appeal both refused to enforce an…