Potato Seeds and Arbitration Seats: Insights from HZPC Americas Corp. v. Skye View Farms Ltd. A Perspective from the Supreme Court of Prince Edward Island
Where the terms of an arbitration prescribe the “seat” or “place” of the arbitration to be Jurisdiction A, but the parties choose to conduct the arbitration in Jurisdiction B, is judicial review of the arbitral award governed by the laws of Jurisdiction A or B? This question was recently considered at first instance by the…